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RESPONSE TO FEDERAL LAND MANAGER AND EPA COMMENTS 

On November 25, 2008, MassDEP submitted for comment a preliminary draft of the Massachusetts 

Regional Haze State Implementation Plan (SIP) to members of the National Park Service, the Fish and 

Wildlife Service, and the Forest Service (collectively referred to as the Federal Land Managers or 

FLMs) and to the U.S. Environmental Protection Agency Region 1 (EPA). On July 31, 2009, MassDEP 

submitted a revised BART chapter to the FLMs and to EPA for further review. The substantive 

comments received and MassDEP’s responses are listed below. 

Commenters: 

1. U.S. Department of Interior National Park Service and U.S. Fish and Wildlife Service, comments 

dated January 23, 2009, [NPS/FWS 01/09]

2. U.S. Department of Agriculture Forest Service, comments dated January 26, 2009, [FS 01/09]

3. U.S. EPA Region 1, comments dated March 24, 2009 [EPA 03/09]

4. U.S. EPA Region 1, comments dated September 17, 2009 [EPA 09/09]

GENERAL COMMENTS

1. Comment: The Commonwealth of Massachusetts (MA) has submitted a well-written draft Regional 

Haze SIP. The draft SIP addresses several important issue areas as discussed below. The draft SIP 

acknowledges the several uncertainties faced by MANE-VU in regards to emission inventories, 

modeling assumptions and modeling results. [NPS/FWS 01/09, FS 01/09]

Response: MassDEP appreciates the FLM’s review and comments.

2. Comment: MA’s SIP is similar to other MANE-VU draft SIPs reviewed. It is comparable with 

New Hampshire’s SIP due to the level of detail and articulate discussion of why MA/MANE-VU made 

the decisions it did. It addresses the Clean Air Interstate Rule (CAIR) in only a minimal way, but it is 

not a CAIR state and did perform a Best Available Retrofit Technology (BART) analysis on all BARTeligible sources (however, there are concerns with BART determinations). It is clear that MA consulted 

with the Class I states in the region and supports the Reasonable Progress Goals (RPGs) for each Class I 

state. However, similar questions arise, is this a committal SIP? Have they dealt with the CAIR vacatur 

effectively? Are the BART determinations incomplete? [NPS/FWS 01/09]

Response: While many of the emission controls contained in the draft SIP’s long-term strategy are in 

effect, certain reductions are dependent on actions MassDEP is committing to, such as the low sulfur 

fuel strategy. Since the time the FLM comments were submitted, EPA has proposed its Transport Rule 

to replace CAIR. MassDEP has updated its draft SIP accordingly, including relying on the Transport 

Rule’s anticipated emissions reductions in Massachusetts as an alternative to BART and as a means to 

meet MassDEP’s commitments regarding its targeted electric generating units (EGUs) (part of the “167 

EGU stacks” strategy). 

SECTION 1: BACKGROUND AND OVERIVEW OF THE FEDERAL REGIONAL HAZE

REGULATION

3. Comment: In the third paragraph of Section 1.1, Massachusetts states, “on the worst 20% of days, 

visibility impairment in the Northeast and Mid-Atlantic Class 1 areas ranges from about 25 to 30 dv.” 
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This statement is inconsistent with the data presented later in Table 5 in Section 32. The table lists the 

baseline 20% worst visibility for MANE-VU Class I areas as 21.7 to 29.0 dv. In addition, in the Section 

1.1 discussion, it would be helpful to include the visibility range (in kilometers or miles) on the worst 

20% days to give the reader a better context. [EPA 03/09]

Response: MassDEP has corrected this Section and added a visibility range.

SECTION 2: REGIONAL PLANNING AND STATE/TRIBE AND FEDERAL LAND 

MANAGER COORDINATION

4. Comment: Why include Canadian provinces in Table 2 when you do not have any information for 

them? At a minimum, explain modeling runs grouped Canadian sources as a whole outside the modeling 

grid. The draft SIP does not discuss the importance (or lack thereof) of international emission sources.

[NPS/FWS 01/09]

Response: MassDEP has deleted Canadian provinces from Table 2.

5. Comment: Section 2 provides a good overview of how MANE-VU functioned and sets up a 

framework for working with FLMs on future reports and reviews. Also includes list of items on which 

the Commonwealth will consult with FLMs between now and 2013. [NPS/FWS 01/09]

Response: MassDEP appreciates this comment and is committed to continuing to work with FLMs.

SECTION 3: ASSESSMENT OF BASELINE AND NATURAL CONDITIONS

6. Comment: Even though MA is not a Class I state, the draft SIP effectively describes the 

methodology used to determine baseline and natural conditions (i.e., default vs. revised visibility 

calculation). Uniform Rate of Progress is not addressed considering it is not a Class I state. [NPS/FWS

01/09]

Response: MassDEP appreciates this comment and notes that the MANE-VU planning process was 

very effective in involving all of MANE-VU in establishing background and natural conditions and 

establishing a uniform rate of progress.

SECTION 4: MONITORING STRATEGY

7. Comment: The Commonwealth did a good job at outlining current monitoring in MA and in Class I 

areas affected by MA. MA is not required to have a monitoring plan, but we may suggest to the state 

that they include a commitment to continue existing monitoring and a commitment to work with Cape 

Cod National Seashore/NPS and EPA to keep the monitoring program together. [NPS/FWS 01/09]

Response: MassDEP will continue these monitoring programs and work with the Cape Cod National 

Seashore/National Park Service and EPA towards this end.

SECTION 6: EMISSIONS INVENTORY

8. Comment: The Commonwealth does an effective job outlining the development and production of 

emission inventories for all sources. Provides summary information by pollutant for each source for 
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2002 and 2018 for all of MANE-VU. Also, includes summary information for the Commonwealth

alone, by pollutant by source type for 2002 and 2018. Conclusion is that MA will reduce total regional 

haze pollutants by 31% compared to MANE-VU’s overall reduction of 29%. MA acknowledges the 

challenges that existed in developing the inventories, including how different RPOs developed 

individual inventories and explains why MANE-VU chose their inventory for modeling runs. 

[NPS/FWS 01/09]

Response: MassDEP appreciates this comment.

9. Comment: Recommend referencing which appendices individual Pechan Technical documents are 

included in within text. [NPS/FWS 01/09]

Response: MassDEP has referenced the Pechan technical documents that are included as appendices. 

10. Comment: In paragraph 4 of Section 6.1.1, Massachusetts states that it revised its inventory of area 

source heating oil emissions by adjusting the sulfur percent used to derive the emission factors from 1.0 

to 0.3. Massachusetts should explain why this change was made. [EPA 03/09]

Response: MassDEP has added an explanation of this change, which states “the sulfur percent used to 

derive the emissions factors was adjusted from 1.0 to 0.3 because the Massachusetts draft 2002 SO2

emissions methodology for commercial and residential distillate fuel oil used the EPA default sulfur 

content of 1% instead of the correct 0.3% value that was implemented in 2001 according to

Massachusetts regulation 310 CMR 7.05(1) and (2).”

11. Comment: Massachusetts should clarify which of the three emission control scenarios for 2018 

emissions is being presented in Sections 6.4 and 6.5. [EPA 03/09]

Response: MassDEP has added a footnote explaining the use of the 2002 MANE-VU Regional 

Baseline Inventory, version 3.

SECTION 7: UNDERSTANDING THE SOURCES OF VISIBILITY-IMPAIRING

POLLUTANTS

12. Comment: The draft SIP only includes SHEN and BRIG as the 2 Class I areas the Commonwealth 

does not impact, even though figures (Figure 26) are included for Dolly Sods. Therefore, we 

recommend including Dolly Sods as a 3rd Class I area that MA does not contribute to (in addition to 

SHEN and BRIG). A follow-up comment is that the draft SIP needs to be consistent in naming the 

Class I areas it impacts. For example, on one occasion the draft SIP includes all Class I areas in MANEVU, and then in this Section 7, BRIG is identified as not being impacted by MA emissions. [NPS/FWS

01/09]

Response: MassDEP has included Dolly Sods in the list of Class I areas not impacted by Massachusetts 

in Section 7. MassDEP has included Figures 21, 26, and 27 to illustrate that emissions from 

Massachusetts do not contribute greater than 0.1 ug/m3sulfate or 2% of sulfate to Brigantine, 

Shenandoah, and Dolly Sods Class I areas, respectively.

13. Comment: VOCs – Organic Carbon (OC) is identified as second largest contributor to RH after 

sulfate. No major commitment made to address OC, other than future regulations dealing with fine 
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particles and visibility impairment may focus on OC (particularly those focused on summertime ozone 

problems in urban centers). It is agreed that further work is needed in the Northeast on OC speciation 

for the development of better emission inventories for visibility planning purposes. [NPS/FWS 01/09]

Response: MassDEP has added the following sentence: “Massachusetts will continue to evaluate 

methods to reduce the contribution of organic carbon emissions to regional haze; however, significant 

visibility improvements will not occur until sulfate-dominated visibility impairment has been reduced.”

14. Comment: NOx – Recommend including explanation why MA has a slight uptick in NOx 

emissions between 1996 and 1999. Same comment for figure 32 & 33, why the uptick in PM10 and 

PM2.5 emissions between 1996 and 1999 for MA. [NPS/FWS 01/09]

Response: MassDEP has added an explanation that for Massachusetts the increase from 1996 to 1999 

of NOx, PM10 and PM2.5 emissions primarily was due to increases in emissions from off-road and 

stationary point sources. The subsequent decline in emissions from 1999 to 2002 is mainly attributable 

to controls in the on-road mobile category, including Enhanced I/M and CA-LEV. There also were 

significant reductions in the stationary point source category, mainly power plants, that are attributable 

to NOx RACT.

15. Comment: Section 7 includes discussion on crustal material and the potential importance to 

Northeast inventories and that more understanding is needed of its importance. Control measures 

targeted at crustal material may prove beneficial. [NPS/FWS 01/09]

Response: MassDEP acknowledges that crustal material is an important contributor to the PM 

inventory and will continue to consider control measures targeted at crustal material through the MANEVU regional planning process.

16. Comment: Massachusetts should explain the increase in ammonia emissions from 1999 to 2002 

shown in Figure 37. [EPA 03/09]

Response: The following paragraph explains the increase in ammonia emissions from 1999 to 2002. 

“Figure 38 shows that estimated ammonia emissions were fairly stable in the 1996 NEI, 1999 NEI, and 

2002 Version 3 MANE-VU inventories for MANE-VU states, with some slight increases observed for 

most states in MANE-VU. This apparent increase in emissions from 1999 to 2002 is due to a difference 

in the models used to generate the emissions data. 1999 emissions were generated using an EPA model, 

whereas the 2002 emissions were generated using the CMU ammonia model described above. The 

CMU ammonia model incorporates categories such as humans, house pets, wild animals, fertilizers, 

soils, and miscellaneous animals that are not incorporated into the EPA model.” 

SECTION 9: REASONABLE PROGRESS GOALS

17. Comment: The draft SIP states MA consulted with NJ even though earlier, the draft SIP states the 

Contribution Assessment did not indicate an impact at BRIG. See also under Long-term Strategy, again 

MA does not include BRIG as impacted by MA emissions. [NPS/FWS 01/09]

Response: While New Jersey and Massachusetts both participated in the overall MANE-VU 

consultation process, MassDEP has removed New Jersey from the list of states Massachusetts 

specifically consulted with.
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SECTION 10: LONG-TERM STRATEGY

18. Comment: Massachusetts commits to adopting the regional measures before 2018 and will include 

an update on the measures in the 5-year review in 2013. [NPS/FWS 01/09]

MA acknowledges the uncertainties in the BOTW inventory due to lack of enforceability and commits 

to evaluating whether they are reasonable to adopt by 2018 and will make such determination in the 

2013 report. [NPS/FWS 01/09]

In regards to the MANE-VU ASK, the draft SIP states “... this long-term strategy to reduce and prevent 

regional haze will allow each state up to 10 years to pursue adoption and implementation of reasonable 

and cost-effective NOx and SO2 control measures as appropriate and necessary.” Highly recommend 

MA includes a statement that the Commonwealth will provide progress reports on each of the Ask items 

in the 2013 review. [NPS/FWS 01/09]

Response: MassDEP has added the following sentence to address these comments: “Massachusetts will 

provide an update on the implementation of the strategies listed in the “Ask” in the 2013 mid-term 

review.”

19. Comment: Editorial comment, 3rd paragraph, 3rd sentence: “...may be subject to...” [NPS/FWS

01/09]

Response: MassDEP has corrected this sentence.

20. Comment: Regarding satisfying 90% SO2 control on 167 stacks: “Current best estimates indicate 

that SO2 emissions will be reduced by 73%. Massachusetts will revise these projections before the 

progress report due in five years, by July 31, 2013. Alternative measures will be pursued if it is 

infeasible to achieve the 90 percent level of reduction at these stacks. Massachusetts will continue to 

evaluate alternative measures to determine whether they are reasonable to adopt and implement by 2018, 

and expects to make that determination in the progress report.” – There are 10 stacks in MA that are in 

the 167 list. Is this statement satisfactory? It clearly states the Commonwealth will not meet 90%, but 

does commit to reviewing this in 2013. [NPS/FWS 01/09]

The MANE-VU EGU strategy includes 90 percent or greater reduction in SO2 emissions from 167 

stacks shown to impact the MANE-VU Class 1 areas. Massachusetts is home to 10 of these stacks. In 

discussing this strategy in Section 10.4.6, Massachusetts references implementation of 310 CMR 7.29, 

which limits SO2 emissions to 6.0 lb/MWh on a rolling monthly average. This rule, however, is not 

currently federally enforceable. Massachusetts should submit this rule to EPA as a SIP revision. Also, 

Massachusetts estimates that SO2 emissions from these 10 stacks will be reduced by 73 percent. What 

additional measures is Massachusetts considering to meet the SO2 reduction shortfall? [EPA 03/09]

Response: MassDEP did not originally anticipate achieving the stated MANE-VU goal of 90 percent 

reduction from each of the 10 stacks located in Massachusetts that are part of the “167 stacks” strategy. 

However, under EPA’s proposed Transport Rule, Massachusetts will achieve the 90 percent reduction, 

and MassDEP has revised the draft Regional Haze SIP to reflect this.
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21. Comment: The November 21, 2008 edition of the draft SIP includes an Executive Summary, 

which is very effective in summarizing the actions intended to be taken by MA. However, as currently 

written, the CAIR vacatur is only noted in a footnote with the argument, that because MA is not a Class 

I state and did not use the CAIR-based modeling to determine RPGs and has performed individual 

BART determinations, the Commonwealth has taken all actions necessary to make their fair share of 

emission reductions as outlined in the draft SIP. Because the vacatur of CAIR is an important issue to 

be dealt with regarding Regional Haze development in the East, we recommend MA include this 

statement directly in the Executive Summary as well as in Section 10, Long Term Strategy. [NPS/FWS

01/09]

When discussing CAIR in terms of reduction programs used for modeling, please include update of 

CAIR status in terms of its actual implementation (i.e., none) and how that will affect MA or MANEVU reporting in 2013. [NPS/FWS 01/09]

Page 102 footnote, need to update with CAIR information [NPS/FWS 01/09]

Footnote 5 needs to be updated in light of the CAIR remand. In addition, EPA recommends that 

Massachusetts include more discussion on CAIR reductions beyond this short footnote. [EPA 03/09]

Response: CAIR was remanded to EPA in December 2008 and remains in place until a replacement 

rule is put into effect. In August 2010, EPA proposed its Transport Rule to replace CAIR. MassDEP 

has updated references to and discussion of CAIR to reflect the proposed Transport Rule.

All MANE-VU Class I states used CAIR as a basis for modeling progress towards the reasonable 

progress goals in their Regional Haze SIPs. For the short-term, this modeling is still valid. MassDEP

believes its Regional Haze SIP includes all measures necessary to obtain its fair share of emission 

reductions needed to meet reasonable progress goals. These measures will be reviewed at the mid-point 

review in 2013 in consultation with Class I states, who may at that time reassess their reasonable 

progress goals. By that time, EPA’s Transport Rule should be final and new modeling results should be 

available. It should then be possible to fine-tune regional haze plans as necessary to take into account 

the Transport Rule and other measures states have implemented. 

22. Comment: Massachusetts discusses the MANE-VU low-sulfur fuel oil strategy. DEP should 

include more detail on the specific steps Massachusetts plans to take to implement this strategy and 

make it federally enforceable, especially with regard to the first “outer zone” state milestone of 2014. 

[EPA 03/09]

Response: MassDEP has added additional detail on the steps it will take to implement the MANE-VU 

low-sulfur fuel oil strategy. In 2011, MassDEP will propose to amend 310 CMR 7.05: Fuels to 

incorporate the low-sulfur fuel oil limits. The final regulation will be submitted to EPA as a revision to 

the Massachusetts SIP, which will make it federally enforceable.

23: Comment: MA commits to investigate measures to mitigate impact from smoke from open 

burning associated with agriculture and forestry management. The Commonwealth commits to 

reviewing existing state regulations associated with open burning in context of Regional Haze. 

Prescribed burning is currently allowed under law with approval by MassDEP. [NPS/FWS 01/09]
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Response: MassDEP has reviewed its open burning regulations and believes its rules and practices are 

sufficient to protect visibility in the Class I areas affected by emissions from Massachusetts sources, 

including agricultural and forestry smoke.

24. Comment: MDEP includes pending regulations to deal with outdoor wood-fired boilers (see 

Regulation of Outdoor Hydronic Heaters). We recommend MDEP update this section, since regulations 

should be on the books at this time (draft SIP states by September 2008), and include the State’s 

intention to submit these regulations as a part of the regional haze SIP. [FS 01/09]

In terms of the MANE-VU Ask, MA does include pending regulations to deal with outdoor wood-fired 

boilers (see Regulation of Outdoor Hydronic Heaters). We recommend MA update this section, since 

regulations should be on the books at this time (draft SIP states by September 2008). [NPS/FWS 01/09]

Massachusetts references the proposal of 310 CMR 7.26(50) to control the emissions from outdoor 

wood-fired boilers. Massachusetts should update this discussion to reflect the adoption of this regulation 

and the DEP should submit this rule to EPA as a SIP revision. [EPA 03/09]

Response: MassDEP has updated Section 10 to reflect finalization of new regulations on 12/26/2008, 

310 CMR 7.26(50) through (54), to control emissions from outdoor hydronic heaters (OHHs, also called 

outdoor wood-fired boilers or OWBs). MassDEP intends to submit 310 CMR 7.26(50) through (54) to 

EPA as a SIP revision to make it federally enforceable.

25: Comment: It would help in our evaluation of the SIP if MDEP would explicitly state which 

“expected” LTS components in Section 10 are currently enforceable and which are being evaluated for 

the 2013 progress report. [FS 01/09]

Response: Section 10.4 identifies ongoing air pollution controls that currently are in place (MassDEP’s 

outdoor hydronic heaters regulations also is in place, as described in Section 10.8). Section 10.5 

identifies additional reasonable strategies (i.e., those embodied in the MANE-VU “Ask”) that are not yet 

enforceable but which Massachusetts has committed to pursue and make enforceable before the 2013 

progress report, including BART/Alternative BART, the low-sulfur oil strategy, and the targeted “167” 

EGU stacks strategy. The MANE-VU “Ask” also identifies continued evaluation of other control 

measures including energy efficiency, alternative clean fuels, and other measures to reduce SO2 and NOx

emissions from all coal-burning facilities by 2018 and new source performance standards for wood 

combustion. MassDEP will continue to evaluate these strategies and provide an update in the 2013 

progress report.

26. Comment: The Forest Service routinely requests that SIPs include language linking the Regional 

Haze Program with the Prevention of Significant Deterioration program. We note that the PSD program 

can be an effective tool to prevent degradation of “Best Days”, and that new sources should be 

consistent with or accounted for in RH SIP revisions. [FS 01/09]

Recommend MA address the importance of reviewing future projected emission growth, e.g. NSR and 

PSD permits, in regards to how the emission growth may impact regional haze and RPGs. [NPS/FWS

01/09] 

Response: The following text has been added to the Regional Haze SIP to address these comments:
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The Prevention of Significant Deterioration (PSD) program applies to all new major stationary sources

(or existing major stationary sources making a major modification) located in an area that is in 

attainment or is unclassified for a pollutant with a NAAQS. A major source is an emissions source that 

has the potential to emit more than 100 tons per year of a regulated pollutant in a listed category or 250 

tons per year in any other category. One of the intentions of the PSD program is to protect air quality in 

national parks, wilderness areas, and other areas of special natural, scenic, or historic value. The PSD 

permitting process requires a technical air quality analysis and additional analyses to assess the potential 

impacts on soils, vegetation and visibility at Class I areas.

MassDEP accepted delegation of the federal PSD program in 1982. In 2003, consistent with its 

delegation agreement, MassDEP returned the program to EPA and EPA Region I assumed the 

responsibility for issuing PSD permits for Massachusetts facilities. As part of the federal fiscal year 

2011 Performance Partnership Agreement with EPA, MassDEP agreed to reverse its earlier decision and 

will take delegation of the PSD program, while simultaneously completing the state regulatory adoption 

of the PSD program for inclusion in the federally enforceable Massachusetts State Implementation Plan. 

In addition, MassDEP has retained its state new source review program, which permits new and 

modified sources of emissions under 310 CMR 7.02 – Plan Approval and Emission Limitations. This 

regulation requires Best Available Control Technology (BACT) for all pollutant emissions and a 

determination that the new or modified source will not cause or contribute to a violation of a NAAQS.

Depending upon the specific pollutant, the new or modified source also may be subject to nonattainment review under 310 CMR 7.00 Appendix A – Emissions Offsets and Non-Attainment Review, 

which requires Lowest Achievable Emissions Rate (LAER).

BEST AVAILABLE RETROFIT TECHNOLOGY (BART)

27. Comment: Like our FLM partners, we are concerned about the adequacy of the BART 

determinations. We do not reproduce their detailed comments below, but support the comments they 

submitted to you. [FS 01/09]

First, the Massachusetts Department of Environmental Protection’s (MDEP) heavy reliance on 

Regulation 310 CMR 7.29(5)(a) as a de facto standard for BART seems to have resulted in less 

adherence to the full five-factor BART analysis presented in the EPA BART Guidelines. [NPS/FWS

01/09]

Second, MDEP has not demonstrated how the SO2 and NOx emission limits in Regulation 310 CMR 

7.29(5)(a) comport with the presumptive SO2 and NOx emission limits in the EPA BART Guidelines. 

For example, Regulation 310 CMR 7.29(5)(a)2.b.i. provides emission limits based on a energy output

basis of 3.0 lbs./MWh for SO2, calculated over any consecutive twelve-month period, recalculated 

monthly, providing for the use of allowances and early reduction credits to meet the emission limit. The 

SO2 presumptive requirement in the EPA BART Guidelines for certain electric generation units (EGUs) 

within 750 MW power plants is either 95% emission control or 0.15 lbs./MMBtu on a heat input basis, 

over a 30-day rolling average without the use of allowances or early reduction credits. The specific 

thermal efficiencies of the various steam power plants would need to be factored into this determination 

for each unit in order to make the necessary comparison. A similar situation exists for NOx emission 

limits. Certainly, the consecutive twelve-month period, recalculated monthly, providing for the use of 

allowances and early reduction credits is more forgiving than the 30-day rolling average without the use 

of allowances or early reduction credits. [NPS/FWS 01/09]
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Third, some units have proposed control technologies (e.g., selective catalyst reduction and spray dryer 

absorber) that are more stringent than the Regulation 310 CMR 7.29(5) control levels, but the permit 

emission limits are only bounded by the Regulation’s stringency. [NPS/FWS 01/09]

Fourth, emission controls for low capacity units were merely assumed to be too expensive to install 

without the rigor of a full five-factor analysis. [NPS/FWS 01/09]

Fifth, additional information has yet to be provided and evaluated (i.e., Mystic Station Boiler #7 and 

Wheelabrator – Saugus Incinerator) before the Regional Haze SIP can be considered to be complete. 

[NPS/FWS 01/09]

Response: MassDEP has revised the Regional Haze SIP (see Section 8) to include an Alternative to 

BART approach that relies on EPA’s proposed Transport Rule and is no longer proposing sourcespecific BART determinations for its EGUs. The Transport Rule would take effect in the same 

timeframe as BART requirements and would require greater reductions in SO2 and NOx than would be 

achieved through BART alone (with the exception of Wheelabrator-Saugus incinerator). 

NOTE: The FLMs and EPA submitted additional detailed comments on MassDEP’s proposed BART 

determinations (see Appendices D-1 and D-4). MassDEP has not responded to those comments since it 

is no longer proposing source-specific BART determinations, except for the Wheelabrator-Saugus 

incinerator (see Comment 31).

28. Comment: MDEP determined that six BART-eligible facilities had a de minimis impact of less 

than 0.1 deciview on the nearest Class I area, so as to not be subject to BART. The NESCAUM 

exemption modeling that documents these conclusions should be included in the SIP as an appendix and 

be referenced in the BART section of the SIP. [NPS/FWS 01/09]

Response: MassDEP added a sentence that references Appendix R that provides details for modeling of 

Massachusetts BART-eligible facilities and Appendices R-1 and R-2 that contain the modeling results.

 

29. Comment: General Electric – Lynn Industrial Boiler #3. NOx emissions from this industrial boiler 

are currently controlled with LNB and OFA. The analysis that was presented, $2,000 - $4,000 per ton 

with 80% NOx reduction for an SCR system, lacks the engineering rigor provided for in the EPA BART 

Guidelines. If a full five-factor BART determination exists that examines SCR and other combustion 

controls, please provide it to the reviewers. Otherwise, the conclusions were derived from an inadequate 

basis and a five-factor BART determination should be developed. [NPS/FWS 01/09]

Response: General Electric – Lynn has applied to MassDEP for a permit cap of less than 250 tpy for 

NOx and SO2 emissions from Unit 3 in order to become exempt from BART requirements; PM10 

potential emissions already are less than 250 tpy. MassDEP intends to issue this permit cap to GE –

Lynn, at which time it will become federally enforceable. Once this permit is issued, General Electric –

Lynn Unit 3 will no longer be BART-eligible. Therefore, no BART determination is being proposed for 

General Electric – Lynn Unit 3. 

30. Comment: Trigen – Kneeland Station Industrial Boiler #3. NOx emissions from this industrial 

boiler are currently controlled with combustion modification and fuel reburning. The analysis that was 

presented lacks the engineering rigor provided for in the EPA BART Guidelines. If a full five-factor 
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BART determination exists that examines SCR and other combustion controls, please provide it to the 

reviewers. Otherwise, the conclusions were derived from an inadequate basis and a five-factor BART 

determination should be developed. [NPS/FWS 01/09]

Response: MANE-VU has identified a set of sources whose potential “degree of visibility 

improvement” is so small (<0.1 ddv) that no reasonable weighting could justify additional controls 

under BART. (Note that the cumulative impact of all of these sources is lower than EPA’s guidance that

states that the threshold for determining whether a source “contributes” to visibility impairment should 

be ≤0.5 dv.) Trigen – Kneeland has been added to this list, despite its modeled impact of 0.146 ddv 

using the MM5 modeling platform, due to two significant errors in the 2002 input data used by MANEVU to screen facilities for their impact on visibility. First, Units 1-4 were included in the modeling when 

only Unit 3 is BART-eligible. Second, the 2002 modeled NOx emissions from Unit 3 were 396 tons, 

rather than the actual 96 tons of NOx emissions. MassDEP believes that modeling using the corrected 

2002 NOx emissions from Trigen - Kneeland would indicate a total visibility impact of <0.1 ddv. 

Therefore, MassDEP considers Trigen – Kneeland to be a source with de minimis impact on visibility. 

31. Comment: Wheelabrator – Saugus Incinerator. MDEP will propose a NOx emission limit on 

12/31/2008 which will become the BART emission limit for this incinerator. Therefore, any comment 

at this time would be premature. However, the Regional Haze SIP can only be considered complete 

when each source that is subject to BART has federally enforceable emission limits. Thus, the 

finalization process should be accelerated so as to meet the needs of the Regional Haze SIP process. 

[NPS/FWS 01/09]

Response: Wheelabrator has NOx control equipment for both units that includes low-NOx burners and 

Selective Non-Catalytic Reduction (SNCR). Wheelabrator’s permitted NOx emission limit under 310 

CMR 7.08(2)(f)3 is 205 ppm (by volume at 7 percent oxygen dry basis, 24-hr daily arithmetic average).

Compliance is determined by continuous emissions monitors (CEMs). MassDEP’s regulatory limit is 

consistent with EPA’s Emissions Guidelines (both 1995 and 2006). However, MassDEP believes that 

the capabilities of current NOx control technologies can achieve emissions lower than EPA’s MACT. 

At MassDEP’s request, Wheelabrator performed furnace gas temperature profiling and conducted SNCR 

optimization testing to determine the capability of further reducing NOx emissions while minimizing 

ammonia slip. The optimization test results indicate that a reduced NOx emissions target of 185 ppm 

(dry, 7% O2) at current boiler operating loads of approximately 150,000 lbs/hr could be achieved with 

the existing SNCR system. Based on MassDEP’s review of Wheelabrator – Saugus’ existing control 

technologies, MassDEP proposes that the NOx emissions rate target of 185 ppm for each of 

Wheelabrator’s units represents BART. 

MassDEP plans to coordinate Wheelabrator-Saugus permit modifications to address the proposed BART 

emissions rate with permit modifications that will be required by revisions to 310 CMR 7.08(2) 

(Municipal Waste Combustors) and 310 CMR 7.19 (NOx Reasonably Available Control Technology 

(RACT)) that MassDEP plans to propose in 2011. Since MassDEP plans to revise these regulations in 

2011 and may propose a presumptive NOx RACT emission limit lower than 185 ppm -- which may lead 

Wheelabrator-Saugus to pursue a source-specific RACT analysis -- MassDEP will require Wheelabrator 

to modify its emissions control plan once these regulations are finalized, which will make the NOx limit 

federally enforceable. This permit modification will be required no later than July 1, 2013. 
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NOTE: The following comments were submitted by EPA on September 17, 2009 after review of 

MassDEP’s July 31, 2009 revised BART determinations.

32. Comment: Massachusetts indicates that the cumulative impact of all of the sources with a visibility 

impact below 0.1 dv results in a visibility impact below the EPA recommended impact threshold of 0.5 

dv. EPA recommends that Massachusetts clarify that this cumulative modeling includes all sources in 

the MANE-VU domain with a visibility impact below 0.1 dv and is not limited to only Massachusetts 

sources. It may also be useful to indicate the number of sources included in the modeling.

Response: MassDEP has made the following clarification: "(Note that the cumulative impact of all of 

these sources in the entire MANE-VU region is lower than EPA’s guidance which states that the 

threshold for determining whether a source “contributes” to visibility impairment should be ≤0.5 dv.)"

33. Comment: EPA recommends that the last paragraph on page [8] be revised as follows:

“Trigen – Kneeland has been added to this list, despite its modeled impact of 0.146 ddv (0.127 ddv from 

NO3) using the MM5 modeling platform, due to two significant errors in the 2002 input data used by 

MANE-VU to screen facilities for their impact on visibility.”

Response: MassDEP has made this change.

34. Comment: For Table 5 there is no text relating to superscript 3 in the fifth column heading 

“Subject to Presumptive BART?3”. Perhaps it is meant to reference footnote 3 which appears back on 

page [2]. However, it would be easier to follow if the note appeared on the same page as the table. 

Response: MassDEP has deleted the superscript, which was unnecessary.

35. Comment: For Table 14, Massachusetts should clarify the difference between the information 

presented in the column labeled “2002 PM Emissions (tpy)” and the column labeled “2002 PM 

Emissions (tpy)*”.

Response: MassDEP has amended the Table to only present emissions at the facility-wide level as 

reported to MassDEP.

36. Comment: Table 14 indicates that several facilities currently operate electrostatic precipitators 

(ESPs) and Massachusetts indicates that no additional controls are warranted for PM. However, if these 

current controls are considered BART, then they must be made federally enforceable. Massachusetts 

should include more information about the current requirements. For example, what are the permit 

limits? Are these limits federally enforceable? If not, how will they become federally enforceable? 

How do these limits compare to the MANE-VU recommended limits of 0.02 – 0.04 lb/MMBtu?

Response: MassDEP has added emission limits for PM to the Table. Brayton Point Unit 4, Salem 

Harbor Unit 4, and Canal Station Units 1 and 2 have PM limits within or below the MANE-VU 

recommended limits of 0.02 - 0.04 lb/MMBtu. The remaining facilities have limits that are close to the 

MANE-VU recommended limits and include Brayton Point Units 1-3 (0.08 lb/MMBtu), Mystic Unit 7 

(0.05 lb/MMBtu), and TMLP - Cleary Flood Units 8 and 9 (0.12 lb/MMBtu). While these limits are 

greater than the MANE-VU recommended limits, these facilities have significantly reduced PM 

emissions since 2002 and CALPUFF modeling of 2002 PM emissions at these facilities suggests an 
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impact of below 0.1 ddv on the worst day, both for each unit and cumulatively. Therefore, MassDEP 

has determined that no additional controls are warranted for primary PM10 because controls have been 

added to all but one of the facilities and the additional cost to install newer, slightly more efficient 

technology is not justified by the potential negligible visibility benefit. The PM limits for these facilities 

are in permits that are federally enforceable because they were issued pursuant to a federally enforceable 

regulation, 310 CMR 7.02, and then were incorporated into each facility’s operating permit, which is 

issued under another federally-approved regulation, 310 CMR 7.00 Appendix C.

37. Comment: Massachusetts should revise its discussion regarding the three VOC sources. Currently, 

the discussion states that reductions expected to occur by January 1, 2010 at Gulf Oil-Chelsea are 

sufficient to satisfy BART requirements, while “no further controls at Exxon Mobile-Everett and Global 

Petroleum-Revere will be required to satisfy BART, given the minor impact of VOC point sources on 

regional haze.” It is not clear how Massachusetts arrived at differing conclusions for these similar 

sources. Furthermore, Massachusetts has not sufficiently explained why these VOC sources merit 

BART review. 

The BART Guidelines (40 CFR Part 51, Appendix Y) state that visibility pollutants include SO2, NOx 

and particulate matter, and that states should exercise judgment in deciding whether VOC and ammonia 

impair visibility in an area. Specifically, Section II.A.3 of the Guidelines states:

“. . . You (the state) need not provide a formal showing of an individual decision that a source of VOC 

or ammonia emissions is not subject to BART review. Because air quality modeling may not be feasible 

for individual sources of VOC or ammonia, you should also exercise your judgment in assessing the 

degree of visibility impacts due to emissions of VOC and emissions of ammonia or ammonia 

compounds. You should fully document the basis for judging that a VOC or ammonia source merits 

BART review, including your assessment of the source’s contribution to visibility impairment.”

Finally, if Massachusetts does determine that these VOC sources merit BART review, then the 

discussion should include an explanation of how any necessary controls are, or will be made, federally 

enforceable. The current discussion does not indicate how, or if, the 2 mg/l requirement at Gulf OilChelsea is federally enforceable.

Response: Consistent with EPA’s BART Guidelines, MassDEP has decided that the three VOCemitting BART sources in Massachusetts do not warrant a BART review at this time, in part because of

the inability to model the contribution of VOCs to visibility impairment. However, MassDEP is 

continuing to evaluate control technologies for reducing VOC emissions from petroleum storage at 

facilities statewide.