GE- Transportofiion 

Aircraft Engines 

Mr. Robert Donaldson 

Department of Environmental Protection 

Bureau of Waste Prevention 

One Winter Street, 8th Floor 

Boston, Massachusetts 02108 

October 18, 2005 

Dear Mr. Donaldson : 

John M.Craynon 

Plant Manager - Environmental, Health & Safety 

1000 Western Ave MD 1609 

Lyn6, MA 01910 

T 781 594 5297 

F 781594 6294 

John.craynon@ae.ge.com 

The General Electric Company (GE) appreciates the opportunity to submit the attached comments to. 

the. Massachusetts Department of Environmental Protection (MA DEP) on the proposed-amendments to 

310 CMR 7.00, dated August 2005. Upon review of the proposed regulations, GE offers these 

comments regarding the revisions to the visible emission limitations set forth in 310 CMR 7.06(1)(c). GE 

has no comments on 310 CMR 7.00 Definitions or on 310 CMR 7.24 - Organic Material Storage and 

Distribution changes. 

if you have any questions regarding these comments, please call Amy Wong, Air Programs Leader at 

the GE-Lynn facility, at 781-594-2382. 

John M. Craynon 

Plant Manager - Environmental Health & Safety 

cc 

enc. 

General Electric Company 
General Electric Company Comments on 

Proposed Amendments to 310 CMR 7.06(1)(c) Visible Emissions 

Submitted October 18, 2005 

The General Electric Company (GE) appreciates the efforts of the Massachusetts Department of 

Environmental Protection (MA DEP) to create an alternative opacity standard that is highly 

protective of the environment while still being flexible and practical for industry. MA DEP 

clearly recognizes that the operation of industrial boilers is inherently subject to variable 

emissions, depending on equipment and facility-specific conditions such as startups and 

shutdowns. However, GE believes that the proposed amendments to the opacity regulations 

require some clarification and minor modification to enhance their practical application. 

310 CMR 7.06(1)(c)1 - Visible Emission Limits Comments/Clarifications 

" In paragraph 7.06(1)(c)l .a ., please correct the citation from 310 CMR 7.06(l)(c)l .f. to 

310 CMR 7.06(1)(c)l .g . No exceptions to the normal operating limits are discussed in 

paragraph 7.06(1)(c)l .f. 

" Based on the statements made by Mr. Robert Donaldson, MA DEP, at the October 3, 

2005, meeting with concerned members of the Associated Industries of Massachusetts 

(AIM), it is GE's understanding that a boiler, served by a visible emission monitor 

equipped with a numeric data reduction system that can print out individual block 

averages, can utilize the opacity exceptions in both paragraphs 7.06(1)(c)l .b . and 

7.06(1)(c)l .c . during the same quarter. However, the implication in the Background 

Information Document accompanying the August 2005 proposed rule is that a facility 

would have to choose between these provisions. Hence, the current proposed rule 

language should be revised to indicate more clearly that the exceptions contained in these 

two provisions are both available to a qualifying source and are not mutually exclusive. 

" GE requests that the language in 7.06(1)(c)l .b . and 7.06(1)(c)l .c . also be revised to 

clarify that these exceptions are applicable on a per boiler basis, not just for the facility as 

a whole. For example, the language in 7.06(1)(c)l .b . should state more explicitly that 

two exceedances over 27% per quarter are allowed for each boiler operating in a facility; 

the two exceedances do not have to be shared among all the boilers in the facility. 

" GE requests that paragraph 7.06(l)(c)l .b . be changed to allow up to two exceedances of 

27 percent per quarter, eliminating the per hour requirement. 

Limiting this exception to two exceedances over 27% in a quarter is sufficiently 

restrictive; it is not necessary to additionally require that they occur in close proximity. 

These two exceedances should be allowed to occur at any time in a calendar quarter. 

Such a revision would make tracking of compliance with this provision easier without 

affecting the intent of this exception. 

" GE requests that the requirements in paragraph 7.06(1)(c)l .c . be changed to a one-hour 

block period in lieu of a one-hour running period to be more consistent with EPAaccepted data reduction methodologies. 
" The language in paragraph 7.06(1)(c)l .c. indicates that the DEP "may" approve the 

exceptions specified in this provision. GE requests that language be clarified to indicate 

that these paragraph 7.06(1)(c)l .c exceptions shall be approved, if consistent with the 

approved Plan of Good Operating Practices (POGOP). 

" For boilers equipped with a visible emission monitor with numeric data reduction opting 

to apply the paragraph 7.06(1)(c)l .c . exceptions and that operate on a limited basis, GE 

requests that the specification of the number of allowed 6-minute elevated incidents 

between 27% and 60% include an alternative absolute minimum (floor) value in addition 

to the basic restriction of 0.1% of operating time. The types of operating conditions 

requiring use of the exceptions allowed in paragraph 7.06(1)(c)l .c . (e.g. startup, 

shutdown, load change) occur most frequently for limited use boilers. This is one 

instance in which more operating time does not correspond to a larger need for an 

exception. 

It is suggested that this alternative floor be set at eleven (11) elevated incidents per 

quarter, which corresponds to about half of the theoretical maximum number of elevated 

incidents that would be allowed for a unit operating continuously (i .e. there are 

approximately 21,900 6-minute periods in a quarter, and 0.1% of 21,900 = 22 allowed 

elevated 6-minute periods for a continuously operating unit). 

Therefore, GE requests that paragraph 7.06(1)(c)l .c, specify that the number of elevated 

incidents greater than 27% but less than 60% per calendar quarter cannot exceed onetenth of one percent (0.1%) of the total 6-minute block averages, or 11 per quarter, 

whichever is greater. 

" For simplification, GE suggests that the phrase "during the one-hour period when a 6-

minute block averages exceeds 27 percent opacity " be deleted from the end of the second 

sentence in paragraph 7.06(1)(c)l .c . In applying the exceptions of this paragraph, boilers 

will not be able to exceed a one-hour average 27% opacity at any time; hence this 

additional phrase is redundant. 

" GE requests that the language in paragraph 7.06(1)(c)l .d . be revised to indicate that a 

boiler may show compliance with the Section 7.06(1)(c) provisions either through 

Method 9 testing or by use of a certified opacity monitor, but it is not required that an 

opacity monitor serve as a direct compliance monitor unless it is requested by a facility 

and specified as such in the Approval of the Plan of Good Operating Practices (310 CMR 

7.06(1)(c) Plan Approval) . 

Even the large utility boilers in Massachusetts, which are subject to the provisions of 

Sections 7.06(1)a and b, and which are equipped with PS-1 certified opacity monitors 

required by the federal Acid Rain Program (40 CFR 75), are not required to use these 

opacity monitors for direct compliance, unless such a requirement is contained in a 310 

CMR 7.02 Plan Approval. In contrast, the industrial boilers that would qualify for 

applicability under Section 7.06(1)(c) are typically equipped with non-PS-1 smoke 

sensors in accordance with 310 CMR 7.04(2) . 

General Electric Company page 2 of 5 October 18, 2005 
It should be noted that opacity monitors subject to PS-1 certification must be located in 

accordance with specific siting criteria, are subject to stringent design criteria, as well as 

initial certification testing, none of which is required for a smoke sensor under 310 CMR 

7 .04(2) . Also, PS-1 opacity monitors are typically calibrated daily, and may have quality 

assurance audits conducted on a quarterly basis, none of which is typically done for a 

smoke sensor. 

Thus, neither the accuracy of the smoke sensors, nor the regulatory provisions in 310 

CMR 7.06(1) justifies a requirement to use opacity monitors as direct compliance 

monitors under Section 7.06(1)(c). 

Based on the comments above, the suggested language for paragraphs 7.06(1)(c)l .b ., 

7.06(1)(c)l .c ., and 7.06(1)(c)l .d .is as follows: 

b. During periods of start-up, shutdown, soot blowing, and other specified 

operating conditions, visible emissions shall not exceed 27 percent opacity 

during any two 6-minute block averages per calendar quarter for an 

individual boiler. 

c. For a facility equipped with a visible emission monitor with a numeric data 

reduction system that can print out individual block averages, the Department 

shall approve visible emissions during periods of startup, shutdown, soot 

blowing and other specified operating conditions that are consistent with an 

approved Plan of Good Operating Practices pursuant to Section 7.06(1)(c)2, 

that exceed 27 percent opacity for one-tenth of one percent (0.1 Yo) of the total 

6-minute block averages for any boiler during any calendar quarter, or 11 

block averages per boiler per quarter, whichever is greater, provided visible 

emissions do not exceed 60 percent opacity during any 6-minute block 

average. At no time can visible emissions exceed 27 percent opacity for more 

than two 6-minute block averages during a one-hour period and the one-hour 

average opacity shall not exceed 27 percent opacity. The one-hour average 

shall be based on a clock-hour. The use of this paragraph 7.06(1)(c)l.c. by a 

qualified source does not preclude the source from also applying 

7.06(1)(c)l .b, for the same boiler during the same calendar quarter. 

d. Compliance with visible emission limits shall be based upon a six-minute 

block average determined either by the procedures set forth in Method 9 (as 

described in 40 CFR Part 60, Appendix A-4), or, at the request of a facility, by 

a visible emission monitor required under the Operating Permit and specified 

as such in the Approval of the Plan of Good Operating Practices under 310 

CMR 7. 06(1) (c). 

Section 7.06(1)(c)2 - Plan of Good OperatinQ Practices (POGOP) Comments/Clarifications 

" The language in paragraph 7.06(1)(c)2 .d should be revised to clarify that only a 

qualitative, descriptive characterization of the "duration" and "frequency" of startup, 

General Electric Company page 3 of 5 October 18, 2005 
shutdown, soot blow, and other specified conditions needs to be provided in the POGOP, 

not specific numeric values. 

Specifying an allowed "frequency" for startup, shutdown and other conditions, for the 

most part is not feasible ; and for certain types of events (like load ramping), specifying a 

time duration may not be appropriate either. These events are not predictable like normal 

operating conditions and therefore it is inappropriate to require facilities to specify 

frequencies. 

" In paragraph 7.06(1)(c)2 .e ., GE requests that only a general description of the need for 

visible emission limitations greater than 15 percent opacity during startup, shutdown, 

soot blowing and any other specified operating condition be required in the POGOP; i .e . 

MA DEP should not require data showing opacity levels greater than 15 percent be 

presented for each boiler and for each condition in order for a facility to apply the 310 

CMR 7.06(1)(c) exception(s) . Opacity during these special conditions cannot be 

predicted, because they are unusual and infrequent occurrences, as evidenced by the data 

presented in GE's February 2004 public comments indicating such exceedances occur 

less than 0.1% of overall operating time. Moreover, despite the continued use of good 

operating practices and ongoing efforts to improve performance, past emissions are not 

necessarily an indicator of future conditions; e.g . the highest value of opacity seen during 

prior startups could be exceeded in a future startup, especially for a facility with limited 

data. Therefore, a facility should be allowed to take advantage of the full range of visible 

emissions limitations allowable under the 310 CMR 7 .06(1)(c) exception(s) rather than 

be held to prior performance levels or specify different limits under paragraph 

7.06(1)(c)2 .f. 

" In paragraph 7.06(1)(c)2 .f, please correct the citation from 7.06(1)(c)b to 7.06(1)(c)1 . 

" Also in paragraph 7.06(1)(c)2 .f., delete the requirement to propose visible emissions 

limitations with which the facility will comply. This implies that MA DEP is requiring 

each facility to propose specific numeric visible emissions limitations for each boiler for 

each special condition. Instead, each facility should simply indicate whether the facility 

will be complying with the visible emission limitations in paragraphs 7.06(1)(c)l .b . or 

7 .06(1)(c)l .c ., or with the limitations in both paragraphs 7.06(1)(c)l .b . and 7.06(1)(c)l .c . 

The justification for this change was discussed under the comment to paragraph 

7 .06(1)(c)2 .e. 

Based on the comments above, the suggested language for paragraphs 7 .06(1)(c)2 .d ., 

7.06(1)(c)2 .e . and 7.06(1)(c)2 .f. is as follows: 

f 

d. Qualitatively characterize approximate durations and frequencies of startup, 

shutdown, soot blowing and any other specified conditions ; 

e. Document the need for visible emission limitations greater than 15 percent 

opacity during startup, shutdown, soot blowing and any other specified 

operating conditions by providing a qualitative summary of past performance; 

Indicate whether the facility will be complying with the visible emission 

limitations in paragraphs 7.06(1)(c)l .b . or 7.06(1)(c)l.c., or with the limitations 

General Electric Company page 4 of 5 October 18, 2005 
in both paragraphs 7.06(1)(c)l .b. and 7.06(1)(c)l .c. during startup, shutdown, 

soot blowing and other specified operating conditions; 

Section 7.060)(c)3 - Department Action Comments/Clarifications 

" In paragraph 7 .06(1)(c)3 .c., delete the language that the MA DEP approval shall specify 

the visible emission limitations for each operating condition. GE requests that the MA 

DEP approval simply state whether the facility's boilers will comply with 7.06(l)(c)l .b 

or 7.06(1)(c)l .c ., or with the limitations in both paragraphs 7.06(1)(c)l .b and 

7.06(1)(c)l .c . as discussed above. 

The suggested language for paragraph 7.06(1)(c)3 .c . is as follows : 

c. A Department approval shall specify the visible emission limitations exceptions 

applicable, (i.e. paragraphs 7.06(1)(c)I.b . or 7.06(1)(c)l .c., or both paragraphs 

7.06(1)(c)l .b. and 7.06(1)(c)l .c. during startup, shutdown, soot blowing and 

other specified operating conditions approved by the Department); and specify 

corresponding monitoring, record keeping and reporting requirements, and 

other conditions necessary to ensure compliance with the visible emission 

limitations contained in the approval. 

Overall 310 CMR 7.06(1)(c) Plan Approval Comments 

Some facilities in Massachusetts have previously received Approvals of Plan of Good Operating 

Practices in which provisions from the prior version of 310 CMR 7.06(1)(c) was cited. GE seeks 

confirmation that the Department will terminate these Plan Approvals upon promulgation of the 

August 2005 proposed version of this regulation, and that facilities will be given the opportunity 

to modify their existing POGOPs before being issued new Plan Approvals. 

Electric Company page 5 of 5 October 18, 2005