ENCLOSURE 2 LIST OF WITNESSES COMMENTS RECEIVEDANDRESPONSE TOCOMMENTS

Enclosure 2 Page 1LIST OF WITNESSES &COMMENTS RECEIVED AT HEARING August 28, 2008

List ofWitnesses: No members ofthe public attended the SIP hearing on August 28, 2008. In addition, no public comments were submitted. The only comments received were fromthe U .S .EPA provided by letter dated August 28, 2008 fromAnne E. Arnold, Manager, Air Quality Planning Unit. Vermont's responses to these comments are presented below .

Enclosure 2 Page 2State of Vermont Response to EPA Comments on the: VERMONT DEPARTMENT OF ENVIRONMENTAL CONSERVATION

Draft State Implementation Plan Revision Supporting Compliance With Requirements for REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) Under the 8-Hr Ozone National Ambient Air Quality Standard (NAAQS)

Adopted on July 18, 1997 EPA Comment 1) The proposed SIP revision does not mention how Vermont verified that no sources exist in the state for the CTGsource categories for which it is making a negative declaration. The state's final submittal should document the basis for these negative declarations (e.g., searches of telephone directories, interviews with field inspection staff, etc.). VT Response to Comment: Vermont utilized several different sources to verify that there were no applicable sources within the CTGcategories for whichwe are making negative declarations. The Permitting database, the annual emission registration database, the Field Enforcement database, and permitting andfield enforcement staffas well as other programs within the Department were consulted in our efforts to determine applicable sources to the CTGcategories. These databases themselves are constantly being updated to ensure they are accurate and complete based on new initiatives and new

information. The SIP submittal has been updated to reflect these efforts in support ofour negative declarations. EPA Comment 2) The state's existing SIP approved rule 5-253.3 Bulk Gasoline Plants and 40 CFR Part 60 Appendix AMethod 27 Section 6 .5, both require the use ofa pressure measurement device capable of measurements within +0 .1 inches ofwater precision. The revised version of the rule that is included in the proposed SIP submittal, however, requires a device capable of measurements "within a +0.5 inches of water precision." It is not clear why Vermont has revised this requirement. VT Response to Comment: Vermont amended this regulation in 2001 due to concerns about the availability of instruments with the necessary ±0.1 inches ofwater precision that also had a 0to 20 inch range. Since the primary purpose ofthe instrument was documenting that the vapor balance systempressure does not exceed 18 inches ofwater (not 18.0 inches) during product loading, Vermont considers an instrument with a +0.5 inches ofwater precision to be more than adequate for determining compliance with this standard. Moreover, such instruments are readily available for subject facilities.

Enclosure 2 Page 3EPA Comment 3) Appendix Bmentions the renumbering ofthe NOx RACT provisions in

Vermont's 5-251 and requests that the new 5-251(3) be incorporated into the SIP. Vermont's final submittal should include the official version ofthe rule, including the adopted and effective date ofthe regulations, as is done in Enclosure 1 for Vermont rule 5-253.3. VT Response to Comment: Enclosure 1 ofthe SIP submittal has been expanded to also include the requested documentationfor rule 5-251 . EPA Comment 4) Vermont's proposal includes addressing RACT for two major VOC sources and three major NOx sources through provisions contained in the operating permits that have been previously issued to these facilities and requesting that these provisions be incorporated into the SIP. This approach is acceptable; however, Vermont's final submittal must include documentation that outlines the technical and/or economic information that forms the basis for the requirements that have been determined to be RACT for these facilities. The permits require the twoVOCsources, Isovolta and Churchill Coatings, to meet an overall 81 percent reduction and a 3.5 pounds ofVOCper gallon ofcoating limit, respectively. These are the presumptive limits in Vermont's VOC RACT rule 5-253.20 . EPApreviously approved this rule as meeting RACT. These limits are consistent with EPAguidance for VOCnon-CTG RACT sources and appear reasonable for these sources. Vermont's NOx RACT rule 5-251(3), however, does not include any presumptive limits. Therefore, Vermont's final RACT SIP submittal should include technicaljustification for the requirements that have been determined to be RACT for the three major NOx sources. (In particular, it is not clear why both ski resorts are required to operate SCRon similar size diesel engines, but one facility is required to meet a 70percent reduction and the other a 90percent reduction.) In addition, excerpted provisions fromthe operating permits for the five facilities are included as Appendices Cthrough G . In its final submittal, Vermont DECshould include the entire official operating permit document for each facility with a strike-through ofall the provisions that Vermont does not want included into the SIP. This would ensure that sufficient testing, monitoring, and recordkeeping provisions for the operations referenced are included in the SIP and that the requirements incorporated into the SIP are not more stringent than the totality of the permit (e.g., by omitting exemptions or other flexibilities that might be present in the operating permit) . VT Response to Comment: EPA's comment on the VOCRACT determinations is noted and no response is necessary. Regarding the NOx RACT determinations for Dalton Hydro, LI,C (formerly Simpson Paper), Killington/Pico Ski Resort Partners, LLC, and Okemo, LLC, VT has added furtherjustification for these RACT determinations in the SIP submittal (see page 21) . In brief, the RACT determination for Dalton Hydro, LLCis essentially unchanged fromthe original RACT order with the exception that the opacity monitoring provisions unrelated to NOx emissions have been removed. The variability in the NOx RACT determinations for otherwise similar ski resorts was a function ofthe different flexibility needs at the resorts, the remaining life ofthe SCRequipped engines Enclosure 2 Page 4and non SCRequipped engines, timing of issuance ofthe permits in conjunction with the

replacement schedules of all other engines at the resorts and the standards those engines would be held to. The number ofengines at each source in conjunction with the ages and emission characteristics ofthose various engines makes a direct comparison between the resorts difficult and not as straight forward as a single emission unit source such as a utility boiler with numerous precedents for RACT determinations. Regarding the comment requesting VT to include the entire permits and to strike-through the permit provisions that are not to be included in the SIP, VT has updated the Appendices accordingly. EPA Comment 5) As noted in the proposal, Vermont intends to adopt regulations for twoof the CTGs EPA issued in 2006 (the industrial cleaning solvents CTGand the offset lithographic printing and letterpress printing CTG) and is submitting negative declarations for the remaining CTGs issued in 2006 and 2007. Vermont should initiate its rulemaking as soon as possible, since rules for the 2006 CTGs were due to EPA in October 2007. VT Response to Comment: EPA's comment is noted andVermont intends to proceed with adoption of the necessary rules as expeditiously as possible given the current staffing limitations.

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