ENCLOSURE 2 

LIST OF WITNESSES 

COMMENTS RECEIVED AND RESPONSE TO COMMENTS 

Enclosure 2 Page 1 
LIST OF WITNESSES & COMMENTS RECEIVED AT HEARING 

August 28, 2008 

List of Witnesses : No members of the public attended the SIP hearing on August 28, 2008. In 

addition, no public comments were submitted. The only comments received were from the 

U.S .EPA provided by letter dated August 28, 2008 from Anne E. Arnold, Manager, Air Quality 

Planning Unit. Vermont's responses to these comments are presented below. 

Enclosure 2 Page 2 
State 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 CTG source 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 CTG categories for which we are making negative 

declarations . The Permitting database, the annual emission registration database, the 

Field Enforcement database, and permitting and field enforcement staff as well as other 

programs within the Department were consulted in our efforts to determine applicable 

sources to the CTG categories. 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 of our negative 

declarations . 

EPA Comment 2) The state's existing SIP approved rule 5-253 .3 Bulk Gasoline Plants and 40 

CFR Part 60 Appendix A Method 27 Section 6.5, both require the use of a pressure measurement 

device capable of measurements within +0.1 inches of water 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 of water precision 

that also had a 0 to 20 inch range. Since the primary purpose of the instrument was 

documenting that the vapor balance system pressure does not exceed 18 inches of water 

(not 18 .0 inches) during product loading, Vermont considers an instrument with a +0 .5 

inches of water precision to be more than adequate for determining compliance with this 

standard . Moreover, such instruments are readily available for subject facilities . 

Enclosure 2 Page 3 
EPA Comment 3) Appendix B mentions the renumbering of the 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 of the rule, including the adopted and effective 

date of the regulations, as is done in Enclosure 1 for Vermont rule 5-253 .3 . 

VT Response to Comment: Enclosure 1 of the SIP submittal has been expanded to also 

include the requested documentation for 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 two VOC sources, Isovolta and Churchill Coatings, to meet an overall 81 

percent reduction and a 3 .5 pounds of VOC per gallon of coating limit, respectively . These are 

the presumptive limits in Vermont's VOC RACT rule 5-253 .20. EPA previously approved this 

rule as meeting RACT. These limits are consistent with EPA guidance for VOC non-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 technical justification 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 SCR on similar size diesel 

engines, but one facility is required to meet a 70 percent reduction and the other a 90 percent 

reduction.) 

In addition, excerpted provisions from the operating permits for the five facilities are included as 

Appendices C through G. In its final submittal, Vermont DEC should include the entire official 

operating permit document for each facility with a strike-through of all 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 VOC RACT 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 further justification for these RACT determinations in the 

SIP submittal (see page 21). In brief, the RACT determination for Dalton Hydro, LLC is 

essentially unchanged from the 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 of the 

different flexibility needs at the resorts, the remaining life of the SCR equipped engines 

Enclosure 2 Page 4 
and non SCR equipped engines, timing of issuance of the 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 of engines at each source in conjunction with the ages and 

emission characteristics of those 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 two of 

the CTGs EPA issued in 2006 (the industrial cleaning solvents CTG and 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 and Vermont intends to proceed 

with adoption of the necessary rules as expeditiously as possible given the current 

staffing limitations. 

Enclosure 2 Page 5