GE Aircraft Engines 

John M. Craynon 

Plant Manager - EH&S 

1000 Western Avenue 

MD164X9 

Lynn, Massachusetts 01910 

Phone: (781) 594-5297 Fax: (781) 594-6284 

June 30, 2004 

Mr. Robert T. Donaldson, Associate Director 

Business Compliance Division 

Bureau of Waste Prevention 

Department of Environmental Protection 

One Winter Street, Eighth Floor 

Boston, Massachusetts 02108 

SENT VIA FAX AND FEDERAL EXPRESS 

Dear Mr. Donaldson: 

Thank you for giving us the opportunity to comment on the proposed amendments dated May 

2004 to 310 CMR 7.00 and 310 CMR 70.00 for engines and combustion turbines. Upon review 

of the proposed regulations, GE has the following comments: 

• Under 310 CMR 7.26(42) - GE requests that MADEP replace "emergency engines and 

turbines" throughout with "emergency or standby engines and turbines." This section 

should be applicable to both emergency and standby engines, in conformity with 

existing Subparts 310 CMR 7.02(8)(i) and 7.03(10), which have historically regulated 

these engine classifications together. 

• GE has a general comment on the applicability of small emergency or stand-by engine 

generators to 310 CMR 7.26(42). This regulation effectively increases regulatory 

obligations by lowering the applicability threshold for small engines. Previously, 

emergency generators with a heat input less than 3 MMBtu/hr would have been 

exempted from plan approval and considered Title V insignificant sources. Under 310 

CMR 7.26(42), as proposed, units as small as 37 kW power output (approximately 

300,000 Btu/hr heat input) installed six months or more after the effective date of this 

subpart, will have to be certified, meet certain operational limitations, and included as a 

significant source/emission unit on a facility's Title V Operating permit, once the 

proposed engine regulations are incorporated into the SIP. 

If implemented, this would place an undue recordkeeping and reporting burden on 

facilities by requiring that information on compliance of these units be included in the 

semi-annual compliance verification. In addition, facilities would be subject to higher 

operating permit fees based on the inclusion of these new, small units. Similarly, as 

mentioned below, the inclusion of existing units rated less than 3 MMBtu/hr heat input 

as significant sources in facility operating permits would result in added paperwork and 

fees with little environmental benefit. 
Mr. Robert T. Donaldson/MADEP 

June 30,2004 

Page 2 of 3 

The emissions from all of these small units are very minor. Most emergency/standby 

units are operated on the order of about 50 hour/year or less, which equates to less than 

0.3 ton NOx per year for a diesel-fired generator with about 370 KW power output (heat 

input rating of about 3 MMBtu/hr), or 0.03 ton NOx per year for a unit with 37 KW 

power output (approximately 300,000 Btu/hr heat input rating) based on highly 

conservative AP-42 emission factors. 

• The stack height and emission dispersion requirements of 310 CMR 7.26(42)(d)4 for 

new emergency engines and turbines are both onerous and unclear. The proposed 

requirement that an emergency engine or turbine with a power output equal to or greater 

than 300 KW, but less than 1 MW have a minimum stack height of ten feet above a 

facility rooftop or its enclosure is impractical. These engines are often located just 

outside of a large industrial building (as they serve as backup to process or lighting 

within the building) with no "enclosure," per se. The new regulations would then 

require constructing a free-standing stack of typically 75 to 100 feet or more in order to 

meet the requirement to be ten foot above the rooftop. This is impractical considering 

these engines operate so infrequently. 

If the engine is less than 300 KW, the requirement under 310 CMR 7.26(42)(d)4.a.i 

states that locations that are subject to downwash of the exhaust be avoided. Locating 

an engine next to an industrial building inevitably would subject it to some downwash. 

These engines need to be located next to buildings since they support the required 

process operations and lighting in a power outage. However, it is unclear as to how to 

determine if a location is subject to downwash, and how much downwash (if any) is 

acceptable. 

• Under 310 CMR 7.05(l)(a)3, 7.26(42)(c), and 7.26(43)(c), regarding the sulfur content 

of fuel, GE believes compliance with this requirement should be contingent upon the 

compliance of refineries with 40 CFR 80. In addition, the compliance date for this 

regulation should be listed in the MADEP regulation as six months after the widespread 

availability of ultra-low sulfur fuel for purchase in Massachusetts. Unless these 

contingent obligations are fulfilled, it will be impossible for regulated facilities to meet 

this fuel sulfur requirement. 

GE proposes that the language of 310 CMR 7.05(l)(a)3 be changed as follows: "On 

and after [six months after effective date] no fuel supplier shall offer for sale, for use in 

any engine rated at a power output equal to greater than 37 kW, or any turbine rated at a 

power output equal to less than 1 MW, any diesel fuel that fails to comply with the 

applicable US EPA sulfur limits pursuant to 40 CFR 80..." 

• Under 310 CMR 7.02(2)(b)29 - "Exemptions from Plan Approval," include in this 

exemption, existing engines and turbines installed prior to [six months of the effective 

date of this subpart] which have a energy input capacity of less than 3 million Btu/hr. As 

currently proposed, the new language will no longer specifically exempt these existing 

small units from plan approval, making their regulatory status in the MADEP 

regulations unclear. Moreover, 310 CMR 7.00 Appendix C(5)(h) currently allows 

facilities to propose that units exempted under 310 CMR 7.02(2)(b)29 likewise be 

exempted from the requirements of 310 CMR 7.00 Appendix C(5)(b). With the proposed 

i 
Mr. Robert T. Donaldson/MADEP 

June 30, 2004 

Page 3 of 3 

change, the classification of existing engines less than 3 MMBtu/hr as insignificant 

sources in Title V will also be uncertain if MADEP elects to incorporate these proposed 

regulations in the state SIP. 

GE proposes that the following language be added to the proposed new language of 310 

CMR 7.02(2)(b)29: "and an individual internal combustion engine such as a 

combustion turbine or reciprocating engine having an energy input capacity of less than 

3,000,000 BTU/hr installed prior to [six months from the effective date]..." 

• As a general comment on these new regulations, GE believes these regulations can be 

simplified by referring to the EPA standards under 40 CFR 89 regulating the 

manufacture of non-road engines. The emission limitations for engines included in 

Table 2 of 310 CMR 7.26(43)(b) that differ from those in 40 CFR 89 is confusing and 

might require manufacturers to design engines specific to Massachusetts requirements. 

Facilities would be at the mercy of the manufacturers to supply them with engines that 

meet Massachusetts requirements. At a minimum, MADEP should consult with engine 

manufacturers on their ability to meet the emission rates in Table 2. 

If you have any questions regarding these comments, please call Amy Wong/GEAE, Air 

Programs Leader at 781-594-2382. 

Sincerely, 

John M. Craynon 

Plant Manager - Environmental Health & Safety 

c: Amy Wong/GEAE