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 

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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 of the 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 from the list on the second full 

paragraph on page 8 . 

The Department has made the suggested correction . 

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 CTG for 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 RA CT 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 CTG for "Leaks from gasoline 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, or potential 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 staff indicate that some of these 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 VOC RACT; 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 VOC and/or NOx RA CT 

approvals. 

8. Table 3 : It appears that the terminal activities in South Portland for the facilities of 

CITGO Petroleum Corporation, ExxonMobil Oil Corporation, and Portland pipe Line 

Corporation would be subject to Maine's Chapter 112, "Bulk Terminal Petroleum Liquid 

Transfer Requirements." If this is the case, Chapter 112 should be referenced in Table 3, 

rather than Chapter 134, (which specifically exempts VOC processes 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 licenses for the facilities 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 review determined that all units/lines at these facilities subject to RA CT are in fact 

being controlled by BACT. 

For example, Dingley Press operates six printing presses and supporting equipment. 

Each press is a web fed heatset offset lithographic printing press and is comprised of 

multiple printing units and dryers. Supporting equipment includes pre press operations, 

bindery/ink jet printing lines, and cold cleaning degreasers. 

The Department's BACT analysis for this operation addressed both pre press and press 

operation emissions, with additional control equipment being found not to be 

economically justified for the Pre press Operations (BA CT was determined to be the 

continuation of good housekeeping practices for Pre-Press operations). 

Press operations are also subject to BAT, and are controlled through the use of either 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 

from Presses #3, #S, #6, #7, and #8. A Quantum 7000 Catalytic Incinerator is used to 

control VOCs from Press #4. 

The Department has added additional detail in Table 3 (see "Notes ") for each of the 

facilities that are controlled by BACT. 

10. Table 3 : For the FMC Corporation, FPL Energy, Huhtamaki Foodservice Inc., and 

Portsmouth Naval Shipyard facilities, Table 3 references NOx single source SIP 

revisions. The appropriate citation for the EPA approval 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 

VOC and 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 Acquisition facility (Old Town) is not subject to federally-approved RACT 

because it is located in Penobscot County, which is included in that portion of Maine 

receiving a section 18269 NOx waiver. The Department has amended its proposal to 

clarify that this facility is exempt from NOx RA CT requirements. 
13 . Table 3 : The Verso Bucksport LLC facility has a typographical error in the SIP 

approval date. The correct citation should be 4/18/00. 

The Department has made the suggested correction .