HARVAR D UNIVERSIT Y 

UNIVERSITY OPERATIONS SERVICES 

ENVIRONMENTAL HEALTH AND SAFETY 

October 28, 2005 

Mr. Robert Donaldson 

Department of Environmental Protection (DEP). 

Bureau of Waste Prevention 

One Winter Street, 8th Floor 

Boston, MA 02108 

Subject: Comments on Proposed Amendments to 310 CMR 7.06(l)(c) Visible Emissions 

Dear Mr. Donaldson: 

Harvard University commends the efforts of Massachusetts DEP to create an alternate visible 

emission regulation that is protective of the environment and is at the same time practical and flexible 

for nonprofit institutions and industrial facilities. As the following comments indicate, Harvard 

University is concerned that some elements of the proposed regulation impose an unworkable 

stringency, while other elements need to be clarified. 

Background 

Harvard University acquired the Blackstone Plant ("the facility") in April of 2003. The facility 

consists of four boilers fired with both natural gas and 0.5% S No. 6 fuel oil. Two boilers were 

installed in 1930 (194 MMBtu/hr each-boilers 5 and 6) and two were installed in 1963 (286 

MMBtu/hr each-boilers 11 and 12.) The facility was designed as steam and electric generating 

facility, but ceased commercial electrical generation in 2001. Since that time, it has operated as a nonbase loaded steam plant whose predominant use is provision of steam to Harvard University. 

Opacity and Engineering Optimization Program 

Blackstone is a mission critical facility, as it supplies steam to academic, research, residential and 

museum buildings, a. Since Harvard's acquisition of the plant, we have aggressively pursued 

equipment, and operational modifications to become a more efficient and cleaner facility. Our efforts 

have been documented to the DEP in numerous letters and reports, the first issued less than 60 days 

following purchase of the facility. Harvard is in the process of installing a new boiler that will 

replace one of the oldest boilers (Boiler No. 5). The new boiler will utilize Best Available Control 

Technology (BACT). It will use natural gas as primary fuel for most of the year, while using ultra 

low sulfur oil (0.003 % sulfur) as secondary fuel. Harvard has also undertaken significant upgrades to 

the existing equipment, including automated combustion controls, burner tip experimental redesign, 

new oil conveyance systems, and an aggressive operator training program. 

Opacity Reduction Program Results 

With the help of a third parly combustion expert, the facility developed a Plan of Good Operating 

Procedures for Opacity Reduction to address short term opacity excursions that occur during special 

conditions such as sootblowing load ramps, startup/shutdown and unavoidable upset conditions. This 

Plan was submitted to DEP in June 2003; a revised version was resubmitted in March 2004. As 

outlined in the opacity reduction plan, the facility completed a number of measures that include: 

Joseph Griffin 

Director 

46 Oxford Street 

Cambridge, MA 0p4g$\ of 4 

Tel 617.495.2370 

Fax 617.495.0593 

joseph_griffin@harvard.edu 
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. Finally, the facility is evaluating the feasibility of 

sootblower system upgrades. 

The following details some of the items addressed under the Plan of Good Operating Procedure: 

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1) Insulate all uninsulated steam lines and insure that 

all traps are functional to prevent any water carryover 

that causes flame sparklers One Time 9/31/04 

2) Install additional trap(s) as required to prevent water 

carryover to the burners One Time 

NA-Determined not 

applicable 

3) Reset the opacity monitor alarm set point to 15% 

from the current 20% value One Time 2/09/04 

4) Check diffuser, tip, and igniter positions One Time 9/31/04 

5) Optimize those positions in the NOx RACT annual 

tuning program One Time 3/03/04 

6) Confirm accuracy, and upgrade if necessary, gauges 

on all oil and atomizing steam lines to the burners One Time 10/31/04 

8) Evaluate reducing the atomizing steam pressure 

when initiating a gun purge One Time 10/31/04 

9) Replace the 02 analyzers on each boiler One Time 1/30/04 

10) Review, implement, and add all modifications to 

the current standard operating procedure into the 

SOMP One Time Ongoing 

11) Train all operators after each operational change One Time Ongoing 

Life wr i ... . 

1) Insulate all uninsulated steam lines to prevent any 

water carryover that causes flame sparklers One Time 9/30/04 

2) Install additional trap(s) as required to prevent water 

carryover to the burners One Time 

NA-Determined not 

applicable 

3) Calibrate and check all transmitters One Time 11/07/04 

4) Reset the opacity monitor alarm set point to 15% 

from the current 20% value One Time 2/09/04 

5) Calibrate and check response set point for each of 

the combustion controllers One Time 2/07/04 

6) Determine the lowest effective atomizing steam 

pressure when initiating a gun purge One Time 2/20/04 

7) Confirm accuracy, and upgrade if necessary, gauges 

•n all oil and atomizing steam lines to the burners One Time 5/15/04 

8) Optimize all controllers and drive units in the NO, 

RACT annual tuning program One Time 3/03/04 

9) Evaluate reducing the steam sootblowing pressure on 

the initial soot blow cycle to '/i of the normal pressure One Time Ongoing 

10) Evaluate a break of six minutes before repeating 

any sootblowing cycle One Time Ongoing 

11) Review, implement, and add all modifications to 

the current standard operating procedure into the 

SOMP One Time Ongoing 

12) Train all operators after each operational change One Time Ongoing 

We have evaluated the impact of the proposed regulations following our extensive opacity reduction 

program. The result of our extensive efforts has been a significant reduction in opacity peaks during 

normal operating conditions. Notwithstanding these considerable improvements, the facility still 

finds the proposed opacity limits onerous during unavoidable operating conditions such as startup/shutdown, burner upsets, and soot blowing. As outlined below, our concern remains with the DEP 

proposal for non-routine operations. Following are the facility's comments on the proposed 

regulation. 

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Proposed 310 CMR 7.06(l)(c)l-Visible Emissions 

• The one-tenth of one percent (0.1%) rule imposes significant penalty on boilers that operate 

only limited hours during a given calendar quarter. Harvard University requests this aspect of 

the rule be amended to exempt units that run only limited hours in any quarter: e.g., units 

with Capacity Factor (ratio of actual to potential quarterly run hours) equal to or less than 25 

percent per quarter. These units could still be regulated by the remaining aspect of 310 CMR 

7.06(l)(c)l.c, "—at no time can visible emissions exceed 27 percent opacity for more than 

two 6-minute block averages during a one-hour period and the one-hour average opacity 

shall not exceed 27 percent opacity during the one-hour period when a 6-minute block 

averages exceeds 27percent opacity. " For units that operate on a continuous basis during 

any given quarter, the one-tenth of one percent (0.1%) rule provides only 22 six-minute 

block allowances for elevated opacity (0.1 % of 21,900 six-minute blocks equals 22 

allowances.) This limited allowance is too restrictive to comply with, especially for older 

units. Harvard University proposes the one-tenth of one percent rule be modified to 0.50 

percent of the total 6-minute block averages during any calendar quarter. 

• Harvard has conducted a rigorous and thorough engineering review and analysis of upset 

conditions in the past two years. Our experience under our Plan of Good Operating Practices 

indicates that it is not technologically feasible to comply with the proposed requirement at 

our facility, given that this is an older, load following steam plant rather than the original 

design of a base-loaded commercial steam-electric plant. Load-following steam plants are 

more susceptible to upset conditions than base loaded plants. The upper cap of 60 percent is 

burdensome especially during unforeseen conditions such as boiler trip, burner or equipment 

upsets, and unanticipated load ramps. In keeping up with the original intent of 310 CMR 

7.06(1 )(c)-giving industry operational flexibility, while still being protective to the 

environment, Harvard University requests that the Department allow certain spikes above 60 

percent: e.g., establishing an absolute number of not to exceed 15 elevated incidences above 

60 percent per calendar quarter. 

• Based on the language in proposed 310 CMR 7.06(l)(c), during periods of start-ups, shut 

down, soot blowing, and other specified operating conditions, it is not clear if facilities need 

to choose to comply with either 310 CMR 7.06(l)(b) or 310 CMR 7.06(l)(c), or if both 

provisions are available for facilities. Hence, the current proposed language should be revised 

to clarify this issue. 

• Applicability of allowed short term opacity excursions under the new proposed regulations is 

not clear. Harvard University requests that the language be clarified to unambiguously state 

that allowances are based on each unit/per visible emission monitor, as opposed to facility 

wide. 

• The language in the new proposed regulation states that the Department "may" approve 

alternate visible emissions during special conditions. Harvard University requests that the 

language be modified to state that the Department will approve alternate visible emissions 

limits during special conditions, provided such alternate visible emissions are detailed in the 

facility's Good Operating Practice Plan as developed by third party combustion experts. 

Proposed 310 CMR 7.06mfc)2.-PIan of Good Operating Practices 

• Based on the current language under 310 CMR 7.06(l)(c)2.d, proposing duration and 

frequency for special conditions is not feasible. Most, if not all, of these conditions are not 

predictable and are characterized by non-routine activities such as burner or equipment 

malfunctions,, and unexpected load ramps. Harvard University proposes that these special 

conditions be well-defined in Plan of Good Operating Practices without specifying duration 

and frequency. 

• Given the nature of special conditions such as short duration and infrequency, predicting their 

future occurrences is not practical. The requirements under 310 CMR 7.06(l)(c)2.f-proposing 

visible emission limits for each special condition is not feasible. Hence, Harvard University 

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requests this requirement be amended to allow facilities to comply with either 310 CMR 

7.06(l)(c)l.b. or 310 CMR 7.06(l)(c)l.c. This will also reduce the Department's regulatory 

permitting burden by avoiding to numerous special conditions for all facilities across the state 

that fall within this proposed regulation. 

• Harvard University submitted its Plan of Good Operating Practice in response to the 

Department's earlier version of 310 CMR 7.06(l)(c), August 3, 2001. Since this new 

proposed regulation differs significantly from the Department's earlier version, Harvard 

University requests the opportunity to modify its Plan of Good Operating Practice to reflect 

the new proposed regulation. 

Other Alternatives 

Harvard University views this rule development as an important issue and supports the Department's 

goals. In the event the Department is unable or unwilling to revise the current language in the 

proposed regulation, and address above concerns, Harvard University believes that there are other 

alternatives: 

• Convene a meeting of those commenting on the proposed rule to obtain a better 

understanding of desired operational flexibility and feasibility; 

• Given the age and the original design of some of the impacted facilities, deal with the 

exceptional circumstances (such as the Blackstone facility) as a separate matter. This 

approach has been taken in both Vermont and New Hampshire, who differentiate between 

older and new units with respect to visible emissions regulations. Harvard University requests 

the Department consider the age of the regulated units during visible emission regulation 

development; 

• Establish a different (e.g. six month) rolling compliance window for accrual of opacity 

excursions to enable a facility to predict and respond to the potential for exceedances; 

• Require that those facilities unable to comply with the regulation implement an update their 

Plan of Good Operating Practice, with regard to both engineering and operational controls; 

• Require those facilities unable to comply with the regulation to develop and implement 

continuous improvement programs in their Plan of Good Operating Practices; 

• Recognize the seasonal load profile of older, load following steam plants, providing 

additional leniency during the winter months during which these facilities may be allowed to 

comply with less restrictive opacity limits. 

Thank you for the opportunity to comment on this matter. I sincerely appreciate the work of the DEP 

to address this difficult issue, and support the goals of the Department. I would be happy to discuss 

the proposed regulation at your convenience. Please feel free to call me at (617) 495-2370 if I can 

provide additional clarification or respond to any questions that you may have. 

Director 

Harvard University 

Environmental Health & Safety Department 

cc: Mohamed Omar, Nick Peters, Doug Garron, Sean Reagan, Andy Finn 

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