STATE OF MAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION

PAUL R . LEPAGE GOVERNOR PATRICIA W . AHO ACTINGCOMMISSIONER September 14, 2011 David Conroy, Chief Air Programs Branch U .S. EPARegion I-NE 5 Post Office Square Mail Code: OEP05-2 Boston, MA02109-3912 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 BestAvailable 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 EPAincorporate 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 EPAdetermined 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 140of 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 Vlicense conditions limiting the amount oftime 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 fromBART. These emissions reductions however, will still take place as a result of federally enforceable Title V license conditions limiting the amount oftime 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 CANCOROAD 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/depLetter to David Conroy

September 14, 2011 Page 2 of2 I trust that these clarifications will address anyoutstanding issues with the Maine Regional Haze SIP, and would like to thank you for your assistance in resolving these concerns. Ifyou should have any questions, please feel free to contact Jeff Crawford of my staffat (207) 287-7647. Sincerely, 

# ~l. ~~°~a Melanie Loyzim, Acting Director Bureau ofAir Quality Cc: Anne Arnold, EPA Anne McWilliams, EPA Jeff Crawford, MDEP Marc Cone, MDEP
Enclosures (1)

PUBLICLaw, 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 AreasPUBLIC Law, Chapter 604, LD 1662,124th MaineState Legislature An ActTo 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 performresearch, 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 notuse 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 ofparagraph 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 andthe Metropolitan Portland AirQuafityControl Region outsidethe 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 Novem

ber - ' > 1991 , "n`~ 2.0%by weight any ; beginningJanuarX 1 2018 the limit forthose regions is 0 . 5% byweight. hi-the (2) In the Portland Peninsula Air Quality Control Region, nea person may not use any Eqttid
¬ essil residual fuel oilwith asulfur contentgreater than 1 .5% byweight ' ,~-'~beginn' gJanuary 1 2018 the limit for that re~ .ion is 0 5%

by weil~ht. anytime after'L144W--V~=

:bV, . (3) Statewide a person mU not use a distillate fuel : ) Begtxnnin Jg_ anuary 1 2016 with asulfur 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 RegularSession - 124th Maine Legislature, page 1PUBLICLaw, Chapter 604, LD 1662, 124th Maine State Legislature An Act To Improve Maine'sAir 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