### Statement ofthe Air and Radiation ManagementAdministration Department ofthe Environment for the Public Hearing Relating to Proposed Amendments to COMAR 26.11.01 and COMAR 26.11.09 Concerning Fuel BurningEquipment that are Required to Demonstrate Compliance with Visible Emissions Requirements using COM Data held on March 3, 2010 Baltimore, MD My name is Diane Franks. I am the Program Manager ofthe Air Quality Planning Program ofthe Air and Radiation Management Administration, Department ofthe Environment.

This public hearing is being held pursuant to the requirements of40 CFR Section 51.102 and Sections 2-301 et. seq. ofthe Environment Article, Annotated Code ofMaryland. It is also being held in conformance with the State Administrative Procedures Act underthe State Government Article, beginning at Section 1 0-1 01

. Notice ofthis hearing appeared in the: Maryland Register on January 29, 2010; MOE's website from January 26, 2010 to March 3, 2010; Baltimore Sun on January 29, 2010; Saint Mary's Enterprise on January 29, 2010; Cumberland Times-News on January 29, 2010; FrederickNews-Post on January 29, 2010: Salisbury Daily Times on January 29, 2010; and the Washington Post on January 28, 2010

. Copies ofthese notices were submitted for the record. Copies ofthis proposed action and supporting documents were made available for review by the State Clearinghouse and are also submitted at this time into the hearing record

. Copies were also made available for public inspection at the Air and Radiation Management Administration offices in Baltimore, Cumberland, and Salisbury, and at all local health departments or local air quality control offices. The purpose oftoday's hearing is to give the public an opportunity to comment on the proposed amendments to CO MAR 26.11

.01 and 26.11.09 related to fuel burning equipment that are required to demonstrate compliance with visible emissions requirements using COM data. 

### Summary The purpose ofthis action is to:1. Amend COMAR 26.11.01.01 to clarify the definition of''Continuous Emission Monitor" (CEM} and add a definition for "Continuous Opacity Monitor" (COM}; 2. Amend Regulation 26.11.01.05 to clarify that submission oftest results, reports, or other information to the Department must be submitted to the Program Manager of the Air Quality Compliance Program and that all records and documentation must be maintained on-site and made available to the Department upon request; 3. Repeal existing Regulations 26.11.01.10 and .11 and adopt new Regulations .10 and .11 in order to clarify which requirements are for COMs and CEMs; 4. Discontinue the use ofTechnical Memorandum 90-01 ''Continuous Emission Monitoring (CEM} Policies and Procedures" for the fuel burning equipment except for Part II "QualityAssurance Requirements for Continuous Opacity Monitoring Systems". This Technical Memorandum 90-01 is incorporated byreference under**26.11.01.11~** and 5. Amend COMAR 26.11.09.05 to: (a) Add new definitions for "Capacity factor" and "Operating time"; (b) Expand the regulation to include revised procedures for demonstrating compliance with visible emissions (VE} requirements for sources that are required to install COMs; (c) Add procedures that under certain conditions, allow fuel burning equipment with flue gas desulfurization (FGD) units to replace COMs with CEMs for particulate matter; and (d) Add enforcement procedures for COMs for fuel burning equipment.
Sources Affected A number ofsource categories such as power plants, cement plants and incinerators are required to install CO Ms. These amendments affect fuel burning equipment ofa certain size which covers boilers, furnaces, stationary internal combustion engines and stationary combustion turbines. Requirements The visible emissions standards applicable to these units remain unchanged. The amount oftime a source is exempt from the visible emissions standard has been reduced and the exceptions are noted here. Exceptions for start up, load changing and other activities have been eliminated. Baseload Units For 2010 and beyond, baseload units are allowed: 2% ofoperating time at greater than the applicable standards (10%or 20%) up to 40.0% opacity. Within the 2%, baseload units are allowed: 0.5% ofoperating time or 5 hours per quarter whichever is greater at 40.0-70.0% opacity; (4} six minute periods greater than 70.0% opacity except for coal fired units with ESP particulate**controls~** Coal fired units with ESP particulate controls are allowed 2.2 hours per quarter above 70.0% opacity. Regardless ofthe quarterly allowances, the daily limit below must be met.


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### Low Capacity Units Lowcapacity = 25% capacity factor or less on a rolling average Units with less than 300 hours operating time per quarter are allowed 12 hours per quarter above the applicable standards (10%or 20%) up to 40.0% opacity; Units with greater than 300 hours operating time per quarter are allowed 20 hours perquarter above the applicable standards (10%or 20%) up to 40

.0% opacity.

Within the 12 and 20 hours, all low capacity units are allowed: 2

.2 hours perquarter at 40.0%-70

.0% opacity (4) six minute periods above 70.0% Regardless ofthe quarterly allowances, the daily limit below must be met. 

### Daily Limit for Both Baseload Units and Low Capacity Units A daily limit of4.1 hours above the standard including: 2.7 hours above the applicable standards (10%or 20%) up to 40.0% opacity and 1.2 hours at 40.0% up to 70

.0% opacity and (2) six minute periods above 70

.0% opacity In 2010, 9 ofthe 17 affected units will install S02 scrubbers. These scrubbers are expected to significantly further reduce particulate matter and opacity

. The owner oft hose units that install scrubbers will have the opportunity to demonstrate that the saturated plume from the scrubber interferes with accurate measurement ofVE and install a Continuous Emission Monitor (CEM) for particulate matter in place ofthe COM. If the CEM provides accurate measurement for particulate matter, the source may discontinue use ofthe COM and provide quarterly datafor particulate matter emissions. 

### Maryland's State Implementation Plan (SIP) This action will be submitted to the U
.S. Environmental Protection Agency (EPA) for approval as part ofMaryland's State Implementation Plan

. 

### Consideration ofComments The Department will consider all comments before making a decision to adopt these amendments to COMAR 26.11

.01 and COMAR 26.11.09.

L:\AQPi annmg and Monitoring\Rcgulation Developm ent Division \CEMS & COMS\Hcaring Slatement\Hcaring Stmt- 26-11..01 & 26- 11..09 Opacity.doc



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