STATE OF MAINE 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

PAUL R. LEPAGE 

GOVERNOR 

PATRICIA W. AHO 

ACTING COMMISSIONER 

September 14, 2011 

David Conroy, Chief 

Air Programs Branch 

U.S . EPA Region I-NE 

5 Post Office Square 

Mail Code: OEP 05-2 

Boston, MA 02109-3912 

Dear Mr. Conroy: 

I am writing to clarify several issues related to Maine's December 6, 2010 Regional Haze State 

Implementation Plan (SIP) submittal, namely: 1) the incorporation of statutory low sulfur fuel 

requirements; 2) the Best Available Retrofit Technology (BART) eligibility status of Dragon 

Products; and 3) the status of emission reductions at the SAPPI Somerset Power Boiler #1 . 

Maine is requesting that EPA incorporate into the Maine SIP only certain portions of the 

Attachment Z legislation "An Act to Improve Maine's Air Quality and Reduce Regional Haze at 

Acadia National Park and other Federally Designated Class I Areas." More specifically, Maine 

wishes to incorporate only 38 MRSA §603-A, sub-§2(A), and as an enclosure to this letter, has 

struck out those portions of the legislation that are not being requested for incorporation. 

With respect to Dragon Products, Maine has reviewed the letters submitted by Dragon Products, 

dated October l, 2010, and November 8, 2010, and after conferring with EPA determined this 

information demonstrates that the facility meets the criteria of a "reconstructed source ." 

Therefore, Dragon Products is not subject to BART. 

Finally, Maine is adding text to page 140 of the Regional Haze SIP narrative to clarify that the 

"other programs" referenced in the Table 11-5 footnote on the SAPPI Somerset Power Boiler #1 

are federally enforceable Title V license conditions limiting the amount of time the #1 Power 

Boiler can be used to incinerate TRS gases. The amended footnote states : 

** The SAPPI Power Boiler #1 was subsequently determined to be exempt from BART. 

These emissions reductions however, will still take place as a result of federally 

enforceable Title V license conditions limiting the amount of time Power Boiler #1 can 

be used to incinerate TRS gases. 

AUGUSTA 

17 STATE HOUSE STATION BANGOR PORTLAND PRESQUE ISLE 

AUGUSTA, MAINE 04333-0017 106 HOGAN ROAD, SUITE 6 312 CANCO ROAD 1235 CENTRAL DRIVE, SKYWAY PARK (207) 287-7688 FAX: (207) 287-7826 BANGOR, MAINE 04401 PORTLAND, MAINE 04103 PRESQUE ISLE, MAINE 04679-2094 

RAY BLDG., HOSPITAL ST. (207) 941-4570 FAX: (207) 941-4584 (207) 822-6300 FAX: (207) 822-6303 (207) 764-0477 FAX: (207) 760-3143 

web site : www.maine .gov/dep 
Letter to David Conroy 

September 14, 2011 

Page 2 of 2 

I trust that these clarifications will address any outstanding issues with the Maine Regional Haze 

SIP, and would like to thank you for your assistance in resolving these concerns. If you should 

have any questions, please feel free to contact Jeff Crawford of my staff at (207) 287-7647. 

Sincerely, 

~l. ~~°~a 

Melanie Loyzim, Acting Director 

Bureau of Air Quality 

Cc: Anne Arnold, EPA 

Anne McWilliams, EPA 

Jeff Crawford, MDEP 

Marc Cone, MDEP 

Enclosures (1) 

PUBLIC Law, Chapter 604, LD 1662, 124th Maine State Legislature 

An Act To improve Maine's Air Quality and Reduce Regional Haze at 

Acadia National Park and Other Federally Designated Class I Areas 
PUBLIC Law, Chapter 604, LD 1662,124th Maine State Legislature 

An Act To Improve Maine's Air Quality and Reduce Regional Haze at 

Acadia National Park and Other Federally Designated Class I Areas 

PLEASE NOTE: Legislative Information cannot perform research, provide legal 

advice, or interpret Maine law. For legal assistance, please contact a qualified attorney . 

An Act To Improve Maine's Air Quality and Reduce Regional Haze at 

Acadia National Park and Other Federally Designated Class I Areas 

Be it enacted by the People of the State of Maine as follows : 

Sec. 1. 38 MRSA §b03-A, sub-§2, as amended by PL 2007, c. 95, §5, is further amended 

to read: 

2. Prohibitions. Except as provided. in subsections 4-,-5- and 89._, iiaa person may not use any liquid 

fossil fuel with a sulfur content exceeding the limits in paragraph A or any solid fossil fuel with a sulfur 

content to heat content ratio exceeding the limits of paragraph B. 

A. The sulfur content for liquid fossil fuels is as follows . 

(1) In the Central Maine, Downeast, Aroostook County and Northwest Maine Air Quality 

Control Regions and the Metropolitan Portland Air Quafity Control Region outside the Portland 

Peninsula Air Oua& Control Region, ne_a person may not use any liquid '-Ss .h'esidual fuel 

oil with a sulfur content greater than '' .`°:u-tmfil -November ' > 1991 , "n `~ 2.0% by weight any 

; beginning JanuarX 1 2018 the limit for those regions is 0. 5% by weight. hi-the 

(2) In the Portland Peninsula Air Quality Control Region, nea person may not use any Eqttid 

¬essilresidual fuel oil with a sulfur content greater than 1 .5% by weight 

' ,~-'~beginn' g January 1 2018 the limit for that re~.ion is 0 5% by weil~ht. 

any time after'L144W--V~=:bV,. 

(3) Statewide a person mU not use a distillate fuel: 

) Begtxnnin Jg_ anuary 1 2016 with a sulfur content greater than 0.005°l° by weight, and (a 

(b) Beginning January 1 2018 with a sulfur content greater than 0.0015% by weight. 

The sulfur content requirements in this subparagraph do not poly to the use of distillate fuel 

for manufacturing purposes. 

s: 

SP0627, Signed on 2010-04-05 00:00:00.0 - Second Regular Session - 124th Maine Legislature, page 1 
PUBLIC Law, Chapter 604, LD 1662, 124th Maine State Legislature 

An Act To Improve Maine's Air Quality and Reduce Regional Haze at 

Acadia National Park and Other Federally Designated Class I Areas 

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Effective 90 days following adjournment of the 124th 

Legislature, Second Regular Session, unless otherwise indicated. 

SP0627, Signed on 2010-04-05 00:00:00 .0 - Second Regular Session -124th Maine Legislature, page 2