## 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 1000Western 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 310CMR 7.00, dated August 2005. Upon reviewof 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 310CMR 7.24 - Organic Material Storage and Distribution changes. if you have any questions regarding these comments, please call AmyWong, 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 (MADEP) to create an alternative opacity standard that is highly protective ofthe environment while still being flexible and practical for industry. MADEP 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 CMR7.06(1)(c)1 - Visible Emission Limits Comments/Clarifications " In paragraph 7.06(1)(c)l .a., please correct the citation from310 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 avisible emission monitor equipped with a numeric data reduction systemthat 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, notjust 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 ofcompliance 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 ofa 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 ofthe number of allowed 6-minute elevated incidents between 27%

and 60%

include an alternative absolute minimum(floor) value in addition to the basic restriction of0 .1%ofoperating time. The types ofoperating 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 fromthe 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 9testing 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 CFR75), are not required to use these opacity monitors for direct compliance, unless such a requirement is contained in a 310 CMR7.02 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, 2005It 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 CMR7.06(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 ofstart-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 quarterfor 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 ofstartup, shutdown, soot blowing and other specified operating conditions that are consistent with an approved Plan ofGood Operating Practices pursuant to Section 7 .06(1)(c)2, that exceed 27percent opacityfor one-tenth ofone percent (0 .1 Yo) ofthe total 6-minute block averagesfor any boiler during any calendar quarter, or 11 block averages per boiler per quarter, whichever is greater, provided visible emissions do not exceed 60percent opacity during any 6-minute block average . At no time can visible emissions exceed 27percent opacityfor more than two 6-minute block averages during a one-hour period and the one-hour average opacity shall not exceed 27percent opacity. The one-hour average shall be based on a clock-hour . The use ofthis paragraph 7 .06(1)(c)l .c. by a qualified source does not preclude the sourcefrom 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 setforth in Method 9 (as described in 40 CFR Part 60, Appendix A-4), or, at the request ofafacility, by a visible emission monitor required under the Operating Permit and specified as such in theApproval ofthe Plan of Good Operating Practices under 310 CMR 7 . 06(1)(c) . Section 7.06(1)(c)2 - Plan of Good OperatinQPractices (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" ofstartup, 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 ofthe 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 CMR7.06(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 offuture 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 ofthe full range of visible emissions limitations allowable under the 310 CMR7 .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 from7.06(1)(c)b to 7.06(1)(c)1 . " Also in paragraph 7.06(1)(c)2.f ., delete the requirement to proposevisible 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. Thejustification 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 andfrequencies ofstartup, shutdown, soot blowing and any other specified conditions ; e . Document the needfor 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 thefacility 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, 2005in 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 DEPapproval 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 fromthe prior version of 310 CMR7.06(1)(c) was cited. GE seeks confirmation that the Department will terminate these Plan Approvals upon promulgation ofthe August 2005 proposed version ofthis 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