Return Receipt Requested 

7099 3400 0009 7461 4951 

SOLUTI A 

February 18, 2004 

Solutia Inc. 

730 Worcester Street 

Springfield, Massachusetts 01151 

7e/413-788-6911 

Karen L. Regas 

DEP/BWP/Business Compliance Division 

One Winter Street, 8t h Floor 

Boston, MA 02108 

Attention: 310CMR7.00 Comments 

Solutia appreciates the opportunity to provide comments on these proposed 

regulations. Solutia's Springfield facility is the Commonwealth's largest chemical 

manufacturing facility, and will be significally impacted by some of the proposed 

revisions to 310CMR7.00. Solutia is concerned by the potential impact of the 

following proposed revisions. 

Change of SSEIS Submittal Date 

Solutia opposes the major change to the submittal date for SSEIS reports. The 

proposed revisions to 310 CMR 7.12 (2) change the deadline from April 15t h of 

each year to March 1s t, reducing the available time to prepare the report from 14 

weeks to only 8 weeks. As a major source, with many emission points, Solutia 

requires all of the available time to prepare and verify our emissions numbers, 

and has, in the past, requested and received extensions in order to be able to 

submit an accurate and complete report. Nearly half of the proposed eight 

weeks will be necessary to obtain final, year end use, throughput, and financial 

data. This information is the starting point for calculating emission data. From 

this point it takes weeks of effort to identify and calculate emission estimates and 

then additional weeks of effort validating and confirming the emission values to 

be reported. Eliminating six weeks of the current submission time seriously 

impacts the ability to provide accurate and complete information that the 

Department requires. Solutia strongly objects to the reduction of SSEIS reporting 

deadline from April 15t h to March 1s t, and requests that this change not be 

incorporated in the final rule. 
Presumptive Approvals for LPAs 

Solutia opposes the proposed requirement to have a Professional Engineer (PE) 

sign and seal all LPA submittals to the DEP (310 CMR 7.02 (4)(d) 6 ). Our 

facility does not routinely use the services of a PE for LPA preparation and 

submittal, so this requirement would mean that we would be forced to pay a 

substantial fee to a consultant engineer each time an LPA is submitted. This will 

greatly increase the cost of these submittals to the facility and cause delays while 

the PE reviews and signs the document. For minor changes that involve small 

emission increases, such as changes to product mix or minor debottlenecking, 

where an LPA is appropriate, PE support is not needed; this is especially true 

since the emissions increase is based on potential and not actual emissions. 

Typically, the actual emissions increase is substantially less than the potential 

emissions increase for changes. 

While it is true that this revision will shorten the approval time to 60 days from the 

current maximum time of 90 days, it is quite possible that the actual approval 

time will increase compared to previous experience. The proposed revision 

ensures that the approval time will be no less than 60 days. It is our experience 

that few, if any, LPAs utilize the full, current, 90 day review period, and most 

were approved in much less time, often less than 60 days. Therefore, not only 

will LPA's cost Solutia more, but also will increase the time to approval in 

contrast to the statement made in the Background Document, Section III, 

Economic Impacts. 

Visible Emissions 

Solutia would also like to make a suggestion with regard to the regulatory 

requirements described as visible emissions. In 310 CMR 7 "smoke density 

indicators" are required of many sources, which in practice are all opacity 

monitors. Our power generation facility uses a, PS-1 compliant opacity monitor to 

determine compliance with visible emission requirements, although we do not 

have a definitive corrolation between opacity and 'the Chart'. The Chart, or 

Ringlemann Scale, is a simple five-point scale that correlates to opacity, but is 

not opacity. Solutia believes that our current approach of continuous opacity 

monitoring with a PS-1 meter is in the best interest of compliance and the 

environment, and would like to request that the regulatory language be updated 

to reflect actual practice and current technology and specify 'opacity' and 

eliminate references to 'smoke density'. 

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Along these lines, we would like to mention current practices for determining 

compliance by the agency. DEP enforcement personnel are trained in EPA's 

Method 9, a visual observation technique to determine opacity levels. They do 

not use 'the Chart'. Accordingly, the Department is not measuring compliance 

against the visible emission regulations for smoke. Solutia requests the that 

Department make changes to 310CMR7.06(1)(a) so as to eliminate any 

reference to 'he Chart', and instead make the regulation relate to the acual field 

practice of regulating opacity. This will have the associated benefit of making 

clear what the compliance standard is for purposes of certifying compliance with 

a Title V Operating Permit. 

Sincerely, 

Roy P. Hart 

Solutia Inc. 

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