"',,D STJll;

\ ,, , .. 

''L PRO"'

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 1

1 CONGRESS STREET, SUITE 1100

BOSTON, MASSACHUSETTS 02114-2023

February 24 2009

Richard A. Valentinetti, Director

Air Pollution Control Division

Vennont Department of Environmental Conservation

Building 3 South

103 South Main Street

Waterbur, Vennont 05671-0402

Dear Mr. Valentinetti:

On January 15 , 2009, we received Vennont's proposed Regional Haze State

Implementation Plan (SIP) and proposed Interstate Transport SIP. EP A staff have

reviewed these proposals and you wil find the Agency s comments in the Enclosures.

If you have any questions on these comments, please contact Ane McWiliams at (617)

918- 1697.

Sincerely,

,.,,

Ane Arold, Manager

Air Quality Planing Unit

Enclosures

cc: Corie Dunn (VT DEC)

Heidi Hales (VT DE 

Toll Free. 1-888-372-7341

Intemet Address (URL) . http://www.epa.gov/region1

Recycled/Recyclable .Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% postconsumer)
Enclosure

EP A Comments on Vermont' s Proposed Regional Haze SIP (1115/09)

1.5 The Basics of Haze

1) When discussing the visibility on the 20 percent cleanest days and 20 percent haziest

days at Lye Brook, it would be helpful to include the visibility range (in kilometers) for

each to give the reader a better context.

1.6 Anatomv of Ree:ional Haze

2) We suggest the first full paragraph on page 11 be revised as follows:

About half of the worst visibility days in Lye Brook occur in the summer when

meteorological conditions are more conducive to the fonnation of sulfate from

S02 and to the oxidations of organic aerosols. In addition

, 

liinter and summer

transport patterns are different, possibly leading to diff-eent contributions from

upwind source regions. As a result The remaining worst visibility days are

divided nearly equally among spring, winter and fall. In addition, winter and

summer transport patterns are different, possibly leading to different contributions

from upwind source regions

1 States Contributine: to Visibilty Impairment at Lve Brook

3) It is not clear why Wisconsin is absent from Table 2.2

, 

States that Contribute to

Visibility Impainnent in the MAN- VU Class I Areas of Acadia, Moosehorn, Great

Gulf, Lye Brook, and Brigantine " when it is included in Table 3.4, "States (Listed by

Regional Planning Organization) and Provinces Contributing to Visibility Impainnent at

Vennont's Lye Brook Wilderness Areas.

2 Meetine: the "Ask" - Vermont

4) This section states

, 

Vennont contains no BART-eligible sources, but intends to meet

the tenns of the MAN- VU agreement by pursuing the low-sulfur fuel oil strategy.

Vennont should include more detail on the mechanism by which this wil become an

enforceable par of the Vennont SIP (e. , does Vennont plan to adopt a rule and submit

it to EP A for approval into the SIP?)

2.4 Consultation Issues

5) Vennont should include more detail regarding its consultation with contributing states

in particular expanding upon the statement that

, 

A few non-MAN-VU states did not

respond to Vennont' s consultation requests or responded by downplaying the magnitude

of their states ' contributions to visibility impainnent at the Lye Brook Wilderness area.

9. Best Available Retrofit Technoloe:v (BART)

6) The last full paragraph on page 82 should be revised as follows:

... there are currently

!! 

BART -eligible sources in Vennont."
A BART-eligible source, which by definition is a source that was installed and operated

between 1962 and 1977, is not something that wil later come into existence. Therefore

the word "currently" is not appropriate.

1 Bart-Elieible EGUs and the Role of CAIR

7) In the third bullet on page 83, Vennont should delete Massachusetts from the list of

non-CAIR states.

10.2.4 Tareeted EGU Strateey for S02 Reduction

8) Vennont should include a description of visibility improvement expected from

controlling the 167 stacks in addition to the discussion of expected improvement in PM

levels.

11.9 Vermont' s Share of Emission Reductions

9) Vennont states that it expects a nearly 85% reduction ofVennont's S02 emissions

from ICI boilers and residential heating units via MAN-VU' s low sulfur fuel oil

strategy. Vennont also cites the implementation of the Low Emissions Vehicle

regulations and Vennont' s regulation controllng Outdoor wood-fire boilers. Vennont

wil need to submit all regulations that the State is taking credit for in its Regional Haze

SIP to EP A for approval into the SIP.
EPA Comment on Vermont Proposed 1l0(a)(2)(D) Transport SIP(1I15/09)

1. In Section V, Vennont should add reference to its proposed Regional Haze SIP.