HARVAR D UNIVERSIT Y 

UNIVERSITY OPERATIONS SERVICES 

ENVIRONMENTAL HEALTH AND SAFETY 

Cambridge/Allston Campus 

February 20, 2004 

Karen L. Regas 

Attention: 310 CMR 7.00 Comments 

DEP/BWP/Business Compliance Division 

MA Department of Environmental Protection 

One Winter Street, 8th Floor 

Boston, MA 02108 

Re: Proposed Changes to Regulations 310 CMR 7, et. seq. 

Dear Ms. Regas: 

The Environmental Health & Safety (EHS) Department of Harvard University is pleased 

to offer the following comments with regard to the referenced action by the 

Massachusetts Department of Environmental Protection (MA DEP). 

As you may know, Harvard University acquired the Blackstone Plant in April of 2003. 

The Blackstone Plant primarily consists of four boilers that are fired on both natural gas 

and No. 6 Fuel Oil. Of the existing boilers operating at Blackstone, two were installed in 

1930 (194 MMBtu/hr each) and two were installed in 1963 (286 MMBtu/hr each). Both 

boilers predate NSPS requirements. Based on the operating history of the recently 

acquired Blackstone Plant, EH&S is requesting that the proposed 310 CMR 7.06(1 )(c) 

opacity standard be modified to allow for occasional, brief, unavoidable opacity 

excursions. 

Since Harvard's acquisition of the Blackstone Plant, we have aggressively pursued 

modifications to eliminate opacity excursions, including recommendations of a third 

party combustion expert who developed an opacity reduction plan. As our opacity 

reduction plan outlines, Harvard has completed measures that include: optimization of 

soot blowing sequencing, third-party review and optimization of soot blowing pressures, 

modification to soot blowing cycle times, increased operator training and awareness and 

decreased intervals of soot blowing operations. In light of these improvements, the 

Blackstone Plant still finds the current opacity limits onerous during unavoidable plant 

operations such as start-up, testing, calibrations, operational upset and soot blowing. 

Given the necessity of these operations, EH&S requests that the DEP considers an 

exemption similar to the proposal submitted February 11, 2004 by General Electric 

Company allowing up to two 6-minute block periods per hour, as long as the one hour 

average is below 27%. In addition, EH&S requests that MA DEP create an exemption 

from the 27% opacity limit for scheduled testing and calibrations when MA DEP is 

informed 24 hours prior to the scheduled event. 

Tel 617.495.2060 

46 Oxford Street Fax 617.495.0593 

Cambridge, MA 02138 www.uos.harvard.edu/ehs/ 
Additionally, EH&S requests the elimination of the proposed paragraph 7.06(l)(c)4. It is 

EHS' opinion that a facility subject to the most stringent oversight by virtue of 310 CMR 

7.00 Appendix C should not be required to make notification within a single business 

day, while facilities regularly exceeding 310 CMR 7.06(l)(a) and (b) limits have no such 

obligation. As you know, pursuant to Appendix C, these exceedances must be reported 

to the MA DEP on a semi-annual basis. 

Thank you for the opportunity to comment and I hope MA DEP gives consideration and 

thought to these comments. If you have any questions or require clarification, please 

contact me anytime at (617) 496-3437. 

Sincerely, 

Miles Walker 

Environmental Engineer 

CC: Joe Griffin, Harvard University EH&S