1 Grcenridge Lane ff2 

Lincoln, MA 

781 259-0219 

February 20,2004 

Ms. Karen Regas 

Massachusetts Department of Environmental Regulation 

BWP/Compliance Division 8th Floor 

1 Winter Street 

Boston, MA 02108 

Subject: Comments on the Proposed Amendments to Massachusetts DEP Regulations 

7.00 

Presented below are comments on the proposed Amendments to Regulations 7.00. Thank you for 

your consideration of these issues. 

1. 702(2)(fl - Exemptions for Exclusions that Contravene an Existing Plan Approval: 7.02(2)(f) 

includes new language that specifies that actions that would contravene existing "monitoring, 

recordkeeping, testing or reporting requirements require a Plan Approval". This language is 

strongly opposed, as it is likely to effectively eliminate any opportunity to streamline or 

improve existing monitoring, testing, recordkeeping and reporting requirements, which in 

some instances is antiquated, overlapping or duplicative. 

It is requested that this language be revised to allow tor consolidation, streamlining, 

improvement, adjustment of monitoring,- recordkeeping, testing and reporting provisions. 

Suggested alternative language is "existing monitoring, testing, recordkeeping and reporting 

requirements cannot be contravened except for purposes of consolidation, streamlining, 

integration, or replacement by an equivalent set of conditions". 

Many existittg 7.02 permits were issued well before new monitoring regulations and 

techniques were developed. For example, at larger sites most opacity monitors are now 

connected to computers, which directly record and aggregate measurement data, making chart 

recorders redundant and imcccsary. However many permits require opacity and other CEMS 

data to be logged on strip chart recorders, Similarly, there is an increasing trend toward 

performing recordkeeping electronically (i.e. in a computer), rather than in a hardcopy 

logbook. Replacement of strip charts and logbooks by their electronic counterparts should 

not require a permit revision. 

More importantly to myself, most Air Plans permits require that CEMS operation comply 

with 40 CFR 60 monitoring provisions, whose requirements overlap and in some cases 

conflict with the newer and more fully elaborated 40 CFR 75 (Acid Rain/NOx Budget) 

regulations. Sources which have an Air Plans permit and arc also in the Acid Rain or NOx 

Budget Program, then are subject to two sets of monitoring regulations, which is both 

complicated and confusing I have been trying to work with both EPA and DEP to largely 

substitute the newer 40 CFR 75 procedures and specifications for the older Part 60 

1 

6130-652 18L doss ID frO 02 
counterparts. However, any such streamlining efforts would be effectively undermined, if it 

should require a Plans Approval to effect such a consolidation of monitoring requirements. 

2. 7.02(4Va)(2) Limited Plan Approval Applicability for Fuel Utilization Facilities: this 

applicability provision indicates that a fuel utilization unit is subject to LPA if the "potential 

emission increase from the said emission unit due to construction, substantial re-construction, 

etc. is < 1 ton/year". Based on this language, it is unclear if potential emissions are evaluated 

against this 1 ton threshold on an individual pollutant basis, or if the potential emissions for 

all air contaminants are added for comparison to this threshold. It is assumed that this 

evaluation is to be performed separately for each air contaminant, consistent with the 

provisions of 7.02(4)(a)(l), If so, it is suggested that the phrase "a single air contaminant 

from the" be inserted after "potential emissions" and before "said emission unit" in tins 

provision. 

3. 310 CMR 7 06(l)(a)-

A. The standards established in 310 CMR 7.Q6(J.)(a) should be expressed in % opacity 

instead of Ringlcman scale increments, as this is the manner in which this provision is 

applied in practice (i.e. replace No. 1 on the Chart with 20% opacity , and No. 2 on the 

Chart with 40% opacity). 

B. It is fuitlici piopwod dial the standards in 310 CMR 7.06(l)(a) be expressed as > 20% 

and > 40%, rather > 20% and £ 40%, consistent with the manner in which all other 

permit limits arc established. With all other permit limits, including 7.06(a)(2), an 

excess emission only occurs if the limit is exceeded, not when it is simply reached. 

4. Opacity Rule 7.06(1 )(c): while in general the new alternative Opacity 7.06(l)(c) provisions 

are supported, certain revisions are requested 

A. The absolute ceiling of 27% should be revised to allow brief periods nf more elevated 

emissions during startup, shutdown, and burner trip-out when such spiking cannot be 

entirely avoided. During periods of highly transient combustion, such as may exist at 

startup, shutdown and burner trips, it may not be feasible to keep fuel and air well mixed 

throughout the combustion zone, so that short opacity (and CO) spikes can occur even if 

proper operating practices are followed. On this basis, most emission regulations, 

including NOx RACT and NSPS, provide exemptions for startup and shutdown periods, 

While the alternative 27% opacity limit does provide some relief for such transient 

periods, it is not sufficient under all startup, shutdown, burner trip conditions, such as 

cold starts, post-outage starts when significant servicing may have been done, etc. Such 

cxcccdances of this 27% ceiling should be relatively infrequent and of short duration if a 

boiler is properly operated, but they appear to be unavoidable. And it does not seem 

appropriate to promulgate a rule that cannot be satisfied at all times, particularly in the 

context of Title V certification requirements. 

It is suggested then that minor exceptions to this 27% ceiling be allowed, if justified in 

the Good Operating Practices plan Such an exception might consist of: 

• During startup, shutdown, and burner trip hours allow up to 2 or 3 6-minute blocks > 

27%, so long as the hourly average = 27%; or 

• During startup, shutdown, and burner trip hours allow up to 2 or 3 6-minute block 

periods up to 40% or 50% opacity. 

2 

GT.20-6Q2 IBL efOSJIO frD 02 
Such exceptions will have negligible effect on overall emissions, but should allow a 

source to remain in compliance at all times, if operating practices are properly designed 

and implemented. 

B. The development of a Good Operating Practices Plan by an independent expert in 

conformance with the proposed 7.06(1 )(c)2. provisions should only be required for 

sources requesting: (1) cither an alternative limit > 27%; or (2) use of the 27% limit for 

atypical special events other than startup, shutdown, burner trips, fuel swapping, and load 

changes. 

While the Good Operating Practices Plan is good idea, it is time consuming and 

expensive to develop, and is not required for any other regulation (RACT, Air Plans, etc.) 

that establishes fixed limits. This Good Operating Practices Plan seems, to some extent, 

to be a vestige of the older versions of this rule, in which either no limit was specified, or 

the limit was variable (i.e. up to 27% for specified special conditions, with the exact 

value depending on the recommendation in the good Operating Practices Plan). 

It is proposed that the 7.06(c)(2) provision be revised to: 

• Require a Good Operating Practices Plan only, if an opacity emission limit in excess 

of 27% is being requested for a particular type of special condition. The Plan should 

provide justification for this exception limit; 

• Require that the plant SOP include procedures for the maintenance of proper opacity 

during startup, shutdown, soot blows, as well as normal operating conditions, but not 

require these procedures to be either developed by an outside expert or submitted to 

MADEP for approval. 

At a minimum provision 7.06(c)2(f) should be eliminated, as it is no longer relevant 

C, All boiler units should be allowed the option of electing to satisfy the 7.06( 1 )(c) opacity 

provisions in lieu of 7.06(1 )(a) and (b), not just boilers < 500 MMBtu/hr mat are in the 

Operating Permit program 

5. 7.19(l3)(a): It is suggested that references to 7.27 in this Section be changed to 7.27/7.2S, as 

the 7.27 Program has effectively expired. 

6. 7.19(13)(c): The letter "M" is missing in the 310 CMR 7.19(13)(c) reference in this Section 

7. 7.54: New Large Combustion Emission Tjnit Rule 

A. 7.54(2)(a) and (b): The definition of a "Large Combustion Emission Unit (LCEU)" 

should clarify whether a Combined Cycle turbine configuration falls within the definition 

of "indirect heat exchanger". The WRSG portion of a combined cycle unit could be 

considered a heat exchanger heated by the products of combustion of the turbine, thereby 

possibly dragging the entire combined cycle unit into being classified as an LCEU. It 

does not seem appropriate that a simple cj'cte combustion turbine would be exempt from 

this rule, but not a combined cycle unit due to the HRSG. 

If DEP wishes to restrict the applicability of this Section to genuine heat exchanger units, 

it would be helpful to explicitly exclude engines (turbines in any arrangement, including 

those equipped with duct burners, as well as reciprocating engines) as is done in other 

sections of the air regulations. 

3 

6I20-BS2 T BL 
It is further suggested that this exclusion extend to combined cycle units with fired duct 

burners to avoid the situation in which the only duct burner portion a combined cycle unit 

is subject to the LCEU rale. 

B. 7.54{2)(n): It is suggested that, the example set provided in the definition of "Pollution 

Control Project" be expanded to include Low NOx Burners (LNB) in order to clarify that 

pollution control projects are not confined to alter treatment equipment, but also extend 

to features that may be part of the combustion unit inherent design, such as LNB. 

C. 7.54{2)(j): The definition of actual emissions should allow all LCEUs to determine postmodification actual emissions from "representative actual annual emissions" occurring 

after implementation of die change. This methodology should not be restricted tn dectnr. 

utility steam generating units. There would seem to be no reason to discriminate against 

the few LCEUs in the state that arc not electric utility units by requiring only them to use 

potential emissions to represent, post-modification actual emissions. LCEU boilers are 

similar enough to electric utility steam generating units to be placed into the same 

category for the purpose of this determination. The method used to calculate postmodification actual emissions can significantly affect project applicability status (i.e. 

whether a project is subject to 7.54). 

Thank you for die opportunity to provide these comments. 

Sincerely: 

Bob Machaver 

781 259-0219 

4 

S *el BI20-652 IBL olDSt t o frO 02 qe j