SUPPLEMENTAL BASIS STATEMENT Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) Revision Under the 1997 8-Hour Ozone National Ambient Air Quality Standard (NAAQS) List of Commenters (1) Anne Arnold United States Environmental Protection Agency Region 1 1 Congress Street, Suite 1100 Boston, MA 02114-2023

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 . Page 4, Footnote 5: reference is being made to the applicable major source thresholds which should read "50" tons per year for VOC . The Department has made the suggested correction. 2. Page 7: As part ofthe mentioned RACT revisions, Maine should highlight the updating of its solvent cleaning rule, Chapter 130, approved into the SIP on 5/26/2005 (70 FR 30367) . Likewise, since there is a Solvent Cleaning Control Techniques Guideline (CTG), "Solvent Cleaning" should be removed fromthe list on the second full paragraph on page 8. The Department has made the suggestedcorrection. 3 . Page 7: Maine determined that its previous asphalt paving regulations "no longer constituted RACT under the 8-hour ozone standard." The revised Maine Chapter 131 regulation, listed in Table 1 as control measure 29, addressing the CTGfor Asphalt paving should be submitted for incorporation in the Maine SIP prior to, or concurrently with, this proposed RACT Certification. The Department is planning to submit the revised Chapter 131 for incorporation into the Maine SIP concurrently with the proposed RACT certification. 4 . Page 10: Reference is made to the Tatermeal single source volatile organic compound (VOC) RACT air emission license amendment being included for incorporation in the Maine SIP as Appendix A . We have reviewed the license and found that it adequately addresses RACT requirements for the Tatermeal facility. The Department would like to thank EPA Region 1 staff for their assistance in completing this air emissions license amendment.5

. Table 1 : The listed control measures 16 and 31 are duplicate entries, both addressing the CTGfor "Leaks fromgasoline Tank trucks and Vapor Collection System(1978) ." We recommend control measure 16 be deleted, since control measure 31 contains additional information and the accurate SIP approval date reference. The Department has made the suggested correction. 6 . Table 3, Page 22: It would be helpful if the emissions listed in Table 3 were labeled as potential or actual emissions. According to the narrative on page 9 it appears that they are licensed (potential to emit) emissions. The emissions listed in Table 3 are licensed, orpotential to emit, emissions. The Department has amended Table 3 to clarify that these are licensed emissions. 7. Table 3: There are several facilities, such as Prime Tanning, for which EPA previously approved a single source RACT determination which are not listed in Table 3. Conversations with Maine DEP staffindicate that some ofthese facilities may have been permanently closed. Maine should clarify this in its RACT Certification. At a minimum, Maine should address the following VOC RACT and NOx RACT approvals: (4/18/00; 65 FR 20754) and (5/20/02 67 FR 35441) for VOCRACT; and (9/9/02; 67 FR 57154) for NOx RACT. The Department has amended its proposal to include and additional table (Table 4) detailing the permanently-closed sources previously receiving VOCand/or NOx RACT approvals. 8 . Table 3: It appears that the terminal activities in South Portland for the facilities of CITGOPetroleumCorporation, ExxonMobil Oil Corporation, and Portland pipe Line Corporation would be subject to Maine's Chapter 112, "Bulk Terminal PetroleumLiquid Transfer Requirements." If this is the case, Chapter 112 should be referenced in Table 3, rather than Chapter 134, (which specifically exempts VOCprocesses subject to CTGbased regulations

. The Department has made the suggested correction. 9 . Table 3: For a few

facilities, "subject to BACT," is listed in table 3 . Although Maine's Chapter 134 exempts VOC-emitting equipment or processes that are subject to Best Available Control technology (BACT), this exemption does not necessarily apply to the entire facility. For example, one coating line at a facility could be subject to BACT, while other coating lines at that facility are subject to RACT . Therefore, more detail should be provided for the facilities where "subject to BACT" is indicated. The Department has reviewed the air emissions licensesfor thefacilities identified in Table 3 that are identified as subject to BACT : Boralex Livermore Falls, LP ; Ir-ving Tanning Company

; Louisiana-Pacific Corporation (New Limerick) ; and Dingley Press.Our reviewdetermined that all units/lines at thesefacilities subject to RACT are infact

being controlled by BACT . For example, Dingley Press operates sixprintingpresses and supporting equipment. Each press is a webfed heatset offset lithographic printing press and is comprised of multiple printing units and dryers. Supporting equipment includes prepress operations, bindery/ink

jet printing lines, and cold cleaning degreasers. The Department's BACT analysis for this operation addressed both prepress andpress operation emissions, with additional control equipment beingfound not to be economicallyjustifiedfor the Prepress Operations (BACT was determined to be the continuation ofgood housekeeping practicesfor Pre-Press operations) . Press operations are also subject to BAT, and are controlled through the use ofeither a Regenerative Thermal Oxidizer (RTO), or Catalytic Incinerator. Dingley uses a Wolverine RTO-25,000 regenerative thermal oxidizer (RTO #1) and a TANN Corporation Model TR 2094 regenerative thermal oxidizer (RTO #2) to control VOCs fromPresses #3, #S, #6, #7, and #8 . A Quantum 7000 Catalytic Incinerator is used to control VOCsfromPress #4. The Department has added additional detail in Table 3 (see "Notes ")for each ofthe facilities that are controlled by BACT. 10 . Table 3: For the FMCCorporation, FPL Energy, Huhtamaki Foodservice Inc., and Portsmouth Naval Shipyard facilities, Table 3 references NOx single source SIP revisions. The appropriate citation for the EPAapproval of these SIP revisions is 9/9/2002, 67 FR 57148) . The Department has made the suggested correction. 11 . Table 3: for the SIP approval dates listed for the Pioneer plastics corporation, the VOCand NOx citations are reversed. The Department has made the suggested correction. 12: Table 3: For the Red Shield Acquisition facility, Table 3 indicates how VOV requirements are being addressed, but does not indicate how the NOx RACT requirements are being addressed. According to the table, emissions are above the 100 tons per year major source threshold for NOx. The Red Shield Acquisitionfacility (Old Town) is not subject tofederally-approved RACT because it is located in Penobscot County, which is included in that portion ofMaine receiving a section 18269 NOx waiver. The Department has amended its proposal to clarify that this facility is exemptfromNOx RACT requirements.13. Table 3: The Verso Bucksport LLCfacility has a typographical error in the SIP

approval date. The correct citation should be 4/18/00 . The Department has made the suggestedcorrection.