Columbia Forest Products 

Aroost0ok County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license renewal application, staff investigation reports and other documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 

M.R.S.A., Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Columbia Forest Products of Presque Isle, Maine has applied to renew their Air 

Emission License permitting the operation of emission sources associated with 

their wood processing facility. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Equipment 

Fuel Burning Equipment 

Boiler#3 • 

Energex 

(Veneer Dryer #1) 

Proctor Dryer 

(Veneer D•er # 1) 

Maximum 

Capacity 

(MMBtu/hr} 

15 

15 

24 

Maximum 

Firing Rate 

1.7 tons/hr 

1.7 tons/hr 

1.9 tons/hr 

Fuel Type, 

% sulfur 

•ood 

29.44 210 gal/hr #2 oil, 0.35% 

3.0.tons/hr wood 

15 107 gal/hr #2 oil, 0.35% 

Control 

Device 

multiclone 

multiclone 

multiclone 

multiclone 

None 

Stack # 

1 

2 

B3 

V1 

V1 

Process Equipment 

Equipment 

Veneer Dryer #2 

Veneer Dryer #3 

Re-Splicing Process 

Wood Handling System 

Production Rate 

40 feet per minute 

Pollution Control 

Equipment 

None 

45•000 lbs. resin/year 

160 feet per min. None V3 

None 

Cyclones #1, #2 & #3 

Stack # 

V2 

fugitive 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Application Classification 

The application for Columbia Forest Products does not include the licensing of 

increased emissions or the installation of new or modified equipment. Therefore, 

the license is considered to be a renewal of current licensed emission units only 

and has been processed through Chapter 115 of the Department's regulations. 

With the fuel limit on Boilers #1, #2 and #3 and Veneer Dryer #1, the facility is 

licensed below the major source thresholds and is considered-a Synthetic minor. 

II. BEST PRACTICAL TREATMENT (BPT) 

A. Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Bureau of Air Quality regulations. BPT 

for existing emissions equipment means that method which controls or reduces 

emissions to the lowest possible level considering: 

the existing state of technology, 

the effectiveness of available altematives for reducing emissions from the 

source being considered; and 

the economic feasibility for the type of establishment involved. 

B. Process Description 

Columbia Forest Pr6ducts produces hardwood (mostly birch and maple) veneer in 

8-foot and 10-foot lengths on two separate veneer lines. Pre-graded logs are 

received and sorted by species in the wood yard. The logs are then conditioned in 

one of nine steam heated "vats" for 42 to 66 hours. The "vats" are similar to 

wood kilns, without the fans. After treatment in the vats, the logs are debarked 

and cut to length. A laser reads the contour of the log and a computer calculates 

how to move the log to obtain the best cutting path. A thin "sheet" of wood 

veneer is sliced off the log with a lathe and wound onto a spool. Veneer rejects 

are either re-spliced or sent to customers for use as is. The remaining tree cores 

are made into pallets for shipping. 

The veneer is un-spooled into one of the facility's three Veneer Dryers. Veneer 

Dryer #1 is a direct-contact dryer with an Energex burner capable of firing wood 

and a Proctor Dryer consisting of three oil-fired heaters. Veneer Dryer #1 serves 

the 10-foot veneer line. Veneer Dryers #2 and #3 are indirect-contact units. It 

passes through the dryer in a looping pattern, while steam at high pressure further 

dries the wood. The last section of the dryer is a cooler which uses ambient air to 

halt the drying process. 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

Departmental 

Findings of Fact an d Order 

Air Emission License 

Defects are marked as the veneer exits the dryer. A computer calculates the best 

way to cut the sheets to get the best value from the wood. Defect-free sheets are 

cut to width, taped for shipping, graded and sorted for shipment to customers who 

use the veneer to make plywood and for woodworking purposes. Sheets with 

defects must be cut to smaller sizes. These pieces pass through a jointer which 

applies glue to the thin edges and joins both sides of the wood. Another machine 

re-splices the pieces, into whole sheet sizes. The re-splicing process may be used 

to obtain specific grain patterns. The re-spliced pieces are trimmed to size, taped, graded, sorted and shipped. 

Columbia Forest Products operates three boilers to provide process steam and 

facility heat. .All three boilers fire wood waste from throughout the process; 

Boiler #3 is. also permitted to fire #2 fuel oil. 

Columbia Forest Products routinely records data based on ten (10) operating periods per year. Each period is between 5 and 6 weeks in duration. For this 

reason, Columbia Forest Products will record and report data for compliance 

purposes on an operating period basis rather than a monthly basis. 

C. Boilers #1 and #2 

Boilers #1 and #2 are operated for process steam and facility heating needs. Each 

boiler has a maximum capacity of 15 MMBtu/hr, firing wood waste (calculations 

are based on wood at 50% moisture with a heat capacity of 4500 Btu/lb.) Boilers 

#1 and #2 were manufactured in 1962 by ERIE and are therefore not subject to 

EPA's New Source Performance Standards (NSPS) Subpart Dc, for steam 

generating units greater than 10 MMBtu/hr manufactured after June 9, 1989. 

Emissions from each boiler pass through multiclones and exhaust through 

separate 65-foot stacks (stacks #1 and #2). 

Columbia Forest Products was previously licensed to fire no greater than I0,000 

tons wood fuel. per year in Boilers #1 and #2. Columbia Forest Products has not 

proposed an increase in this limit and shall continue to be limited to firing no 

greater than 10,000 tons per year of wood in Boilers #1 and #2 on a ten-period rolling total basis. 

A summary of the BPT analysis for Boilers #1 (15 MMBtu/hr) and #2 (15 MMBtu/hr) is the following: 

1. Chapter 103 regulates PM emission limits. The PM10 limit is based on APt42 

data dated 9/03 for the combustion of bark and wet wood controlled with a 

mechanical collector. 

2. SO2, NOx, CO and VOC emissions rates are based on AP-42 emission factors 

dated 9/03 for wood combustion. 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

) 

4 

Departmental 

Findings of Fact and Order 

Air Emission. License 

Visible emissions from each of the boiler's stacks (Stacks #1 and #2) shall not 

exceed 30% opacity on a 6-minute block average, except for 2 six-minute 

block averages in a 3-hour period. 

D. Boiler #3 

Columbia Forest Products installed Boiler #3 in 2003. The boiler has a maximum 

design heat input capacity of 24 MMBtu/hr firing wood at a rate of 1.9 tons per 

hour (calculations are based on wood at 50% moisture with a heat capacity of 

4500 Btu/lb.) 

Boiler #3 is also equipped with a secondary oil-fired burner that will be 

disconnected during periods of wood fire and moved into place when needed to 

provide supplemental heat during wood start-up or periods when wood fuel is 

unavailable. The secondary burner will fire #2 fuel oil or kerosene with a 

maximum design heat input capacity of 29.4 MMBtu/hr capable of firing oil at a 

rate of 210 gallons per hour. 

Since Boiler #3 has a maximum heat input capacity greater than 10 MMBtu/hr, 

and was manufactured in 2003, the boiler is therefore subject to NSPS Subpart Dc 

for steam generating units greater than 10 MMBtu/hr and manufactured, after 

June 9, 1989. The following are the applicable requirements from the subpart: 

1. Standard for sulfur dioxide: 60.42c; 

2. Emission monitoring for sulfur dioxide: 60.46c; and, 

3. Reporting and record keeping requirements: 60.48c. 

Air Emission License A-353-71-H-R established the BACT requirement for fuel 

oil sulfur content at no greater than 0.35% sulfur by weight. In accordance with 

40 CFR Part 60.42c, paragraph h. (1), Columbia Forest Products shall 

demonstrate compliance with SO2 emissions limits and fuel oil sulfur limits 

through certification from the fuel oil supplier. 

In accordance with 40 CFR Part 60.46c(e) the SO2 emission monitoring 

requirements of 40 CFR Part 60.46c shall not apply to Columbia Forest Products 

where the facility shall demonstrate compliance with SO2 standard based on fuel 

supplier certification as described in 4.0 CFR Part 60.48c(f)(1). 

Columbia Forest Products shall comply with the applicable reporting and record 

keeping requirements of 40 CFR Part 60.48c. 

Boiler #3 is equipped with a high efficiency multiclone collector for particulate 

control, The multiclone has a manufacturer's guarantee to have higher control 

efficiency than standard conventional multi-tube cyclones, 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

Air Emission License A-353-71-H-R established the BACT determination for 

CO emissions from Boiler #3 which was based on the proposed Industrial Boiler 

MACT statidard for CO. Boiler MACT (40 CFR Part 63 Subpart DDDDD) applies to facilities that are major sources of Hazardous Air Pollutants. Although Columbia Forest Products is not such a source and therefore not subject to the 

Boiler MACT standards, CO emission limits during wood-firing continue to be 

based on the Boiler MACT CO standard for new or reconstructed large solid fuel 

boilers. 

The promuigated standard is 400 ppm on a dry basis, corrected to 7% 02, which 

converts to approximately 0.405 lb/MMBtu using the Fuel Factor Formula shown 

below: 

ib/MMBtuco :Fawood×Mw ×(COconc.[ppmv]• 20.9 

385 •, • J× 20.9-%O 2 

Where: 

lb / MMBtuco CO concentration in lb/MMBtu 

Fd .... a The volume of dry exhaust gas produced by the combustion of one 

MMBtu of wood at zero excess air. Its value is 9240 dscf/MMBtu. 

M The molecular weight of CO. 

CO conc. [ppmv] The concentration of CO in parts per million by volume. 

%02 The percent excess oxygen. 

Columbia Forest Products was previously licensed to fire no greater than 15,000 

tons wood fuel per year and 1,250,000 gallons per year of #2 fuel oil in Boiler #3. 

Columbia Forest Products has not proposed an increase in this limit and shall 

continue to be limited to firing no greater than 15,000 tons wood fuel per year and 

1,250,000 gallons per year of #2 fuel oil in Boiler. #3 on a ten-period rolling total 

basis. 

A summary of the BPT analysis for Boiler #3 (24 MMBtu/hr firing wood and 

29.44 MMBtu/hr firing oil) is the following: 

1. BPT for emissions of PM from the firing of wood is 0.17 lb/MMBtu as 

guaranteed by the cyclone manufacturer. 

2. BPT for emissions of PM•0 from the firing of wood is 0.10 lb/MMBtu as 

guarant•ed by the cyclone manufacturer. 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

3. BPT for emissions of PM and PM•0 from the firing ofoil is 0.10 lb/MMBtu as 

guaranteed by the cyclone manufacturer. 

4. SO2 emissions from the firing of wood are established using AP-42 factors 

dated 3/02. 

5. SO2 emissions from the firing of oil are regulated by 40 CFR 60.42c. BPT for 

Boiler #3 is the use of fuel oil with a sulfur content not to exceed 0.35% by 

weight, which meets the requirements of 40 CFR 60.42c(d). SO2 emission 

limits from the firing of oil are based on the firing of fuel oil with 0.35% 

sulfur, by weight. 

6. NOx and VOC emission limits were calculated based on AP-42 emission 

factors dated 3/02 for wood combustion and 9/98 for fuel oil combustion. 

7. CO emissions from the firing of wood are based on the Boiler MACT CO 

standard for new or reconstructed large solid fuel boilers of 400 ppm on a dry 

basis, corrected to 7% 02. 

8. CO emissions from the firing of oil were calculated based on AP-42 emission 

factors dated 9/98. 

9, Visible emissions during periods of wood combustion or during periods of 

combusting wood and oil in combination shall not exceed 30% opacity on a 

6-minute block average, except for no more than two 6-minute block averages 

in a 3-hour period. 

10. Visible emissions during periods of oil combustion only shall not exceed 20% 

opacity on a 6-minute block average, except for no more than two 6-minute 

block averages in a 3-hour period. 

E. Veneer Dryer #1 

Columbia Forest Product's current license allows for the operation of a direct 

contact veneer dryer designated Veneer Dryer #1. The dryer was manufactured in 

1973 by Proctor Schwartz to burn oil and was later modified in 1986 to also burn 

wood. Veneer Dryer #1 utilizes the exhaust gases from the combustion of the 

wood or #2 fuel oil to dry veneer. 

The Veneer Dryer #1 makes use of an Energex Combustion unit to fire wood at a 

maximum design heat input capacity of 27 MMBtu/hr firing wood with a 50% 

moisture content. Veneer Dryer #1 also makes use of three #2 fuel oil firing 

burner units (designated Heaters #1, #2 and #3) to supply combustion gases to the 

dryer during periods that wood is not available. The three #2 fuel oil firing 

burners have maximum design heat input capacities of 5.0 MMBtu/hr each for a 

total maximum design heat input capacity of 15 MMBtu/hr. 
Colu mbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

Veneer Dryer #1 exhausts to a 28.6 foot high stack. A previous ambient air 

quality analysis showed that that Veneer Dryer #1 would not meet Maine 

Ambient Air Quality Standards during periods of wood firing unless the stack 

height was raised to 65.0 feet. A recent ambient air quality analysis determined 

that Columbia Forest Products does not exceed Maine Ambient Air Quality Standards at the current stack height during periods of firing only #2 fuel oil with 

a sulfur content of no greater than 0.35% sulfur by weight. 

Columbia Forest Products shall raise stack #V1 and submit documentation to the 

Department indicating that the Veneer Dryer's stack has been extended to 65-feet 

before wood is fired in the Energex wood burner in Veneer Dryer #1. 

Veneer Dryer #1 is equipped with a high efficiency multiclone collector for 

particulate control during periods of wood-firing. The multiclone has a 

manufacturer's guarantee to have higher control efficiency than standard 

conventional multi-tube cyclones. 

Columbia Forest Products was previously licensed to fire no greater than 8,760 

tons wood fuel per year and 250,000 gallons per year of #2 fuel oil in Veneer 

Dryer #1. Columbia Forest Products has not proposed an increase in this limit 

and shall continue to be limited to firing no greater than 8,760 tons wood fuel per 

year and 250,000 gallons per year of #2 fuel oil in Veneer Dryer #1 on a 

ten-period rolling total basis 

VOC lb/hr emission rates for Veneer Dryer #1 firing wood and oil characterize 

emissions from the combustion process only and do not include VOC emissions 

from the drying of hardwood veneer. Emissions from the drying of veneer are 

addressed in the 'Veneer Drying Process VOCs' section of this license. 

A summary of the BPT analysis for Veneer Dryer #1 (27 MMBtu/hr firing wood 

and 15 MMBtu/hr firing oil) is the following: 

1. Chapter 10)-regulates PM emission limits from the firing of oil. The PMl0 limit is based on the PM limit. 

2. BPT for emissions of PM from the firing of wood is 0.17 lb/MMBtu as 

guaranteed by the cyclone manufacturer. 

3. BPT for emissions of PM•0 from the firing of wood is 0.10 lb/MMBtu as 

guaranteed by the cyclone manufacturer. 

4. SO2 emissions from the firing of wood are established using AP-42 factors 

dated 3/02. 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

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Departmental 

Findings of Fact and Order 

Air Emission License 

5. MEDEP Chapter 106 regulates the sulfur content of the fuel oil fired in 

Veneer Dryer #1. BPT for Veneer Dryer #1 is the use of fuel oil with a Sulfur 

content not to exceed 0.35% by weight, which meets the requirements of 

MEDEP Chapter 106. SO2 emission limits from the firing of oil are based on 

the firing of fuel oil with 0.35% sulfur, by weight. 

6. NOx, CO and VOC emissions from the firing of oiI are based on AP-42 

emission factors dated 9/98. The VOC lb/hr emission rate does not include 

VOC emissions from the drying of hardwood veneer. 

7. NOx, CO and VOC emissions from the firing of wood are based on AP-42 

emission factors dated 9/03. The VOC lb/hr emission rate does not include 

VOC emissions from the drying of hardwood veneer. 

8. Visible emissions from Veneer Dryer #1 during periods of wood firing shall 

not exceed 30% opacity on a 6-minute block average, except for two 6-minute 

block avbrages in a 3-hour period. 

9. Visible emissions from Veneer Dryer #1 during periods of oil firing shall not 

exceed 20% opacity on a 6-minute block average, except for two 6,minute 

block averages in a 3-hour period. 

F. Veneer Drying Process VOCs 

Along with the Wood and #2 fuel firing Veneer Dryer #1, Columbia Forest 

Products is also currently licensed to operate an indirect contact veneer drying 

kiln (designated Veneer Dryer #2). Veneer Dryer #2 utilizes steam supplied from 

the facility's boiler units to dry hardwood veneer. Columbia Forest Products 

plans to install a second new indirect contact veneer drying kiln (designated 

Veneer Dryer #3). Veneer Dryer #3 is manufactured by Babcock and utilizes 

steam heat exchange coils (radiators) to heat the interior of the dryer. Columbia 

Forest Products curcently dries wood in five to six week drying cycle periods, 

with 10 drying cycles periods occurring in a 12-month period. 

Columbia Forest Products expects to exclusively dry hard woods in Veneer 

Dryers #1, #2 and #3, which will include oak, maple, birch and possibly poplar. 

VOCs are the criteria pollutant associated with the drying of wood. Columbia 

Forest Products shall be restricted to the following VOC emissions from the 

drying of wood: 

Equipment 

Veneer Dryer #1 

VOC Emissions 

Pounds per hour (lb/hr) 

3 

Tons per year (ton/yr) 

13.1 

Veneer Dryer #2 1 4.4 

Veneer Dryer #3 3 13.1 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

Due to lack of existing data for emissions from hardwood species, VOC 

emissions calculations are based on emissions testing performed on the Veneer 

Dryers #1 and #2 at the Columbia Forest Product's Presque Isle facility in 1995. 

Columbia Forest Products has proposed an emission factor for the drying of 

hardwood veneer at their Presque Isle facility of 0.0234 pounds of VOC per 1,000 

square feet of veneer dried (lb/ft 2) based on the above mentioned emission testing. 

In order to demonstrate compliance'with the VOC emissions limits, Columbia 

forest products shall maintain VOC emission records .for the facility's veneer 

drying units. VOC emission calculations shall be based on the above mentioned 

emission factor for the drying of hardwood veneer and the square feet of veneer 

dried. The records shall be maintained on a ten-period rolling total basis. The 

record shall be updated on a schedule that coincides with the facility's drying cycle schedule. 

G. Wood Fuel Handling System 

Columbia Forest Products utilizes three cyclones in their wood fuel transfer 

system to control wood dust. Wood waste and dust-laden air are blown to each 

cyclone to separate the wood particles from the air. Cyclones #1 and #2 are 

located, or• the wood fuel storage building. Wood waste and bark generated from 

the debarking and initial processing of the incoming wood is blown to Cyclones #1 and #2. The wood waste and wood dust drops onto a conveyor system and is 

delivered into the Boilers #1, #2 and #3 fuel bin. 

Cyclone #3 sits atop the waste sawdust silo. This silo is the fuel source for the 

Energex combustion system of Veneer Dryer #1. Wood waste generated from the 

production end of the veneer process is hogged and blown to Cyclone #3, where 

the wood waste and wood dust drops into the waste sawdust silo. 

Columbia Forest Products shall establish a system of maintenance, inspection and 

repair for the wood dust handling system, which shall allow for a monthly inspection of the system and Columbia Forest Products shall document 

compliance by means of a maintenance, inspection and repair log. 

Visible emissions from any cyclone shall not exceed 20% opacity on a 6-minute 

block average basis, except for no more than one 6-minute block average in a 

1-hour period. 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

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10 

Depar[mental 

Findings of Fact and Order 

Air Emission License 

H. Splicing Process VOCs and HAPs 

VOC emissions are generated as a result of the resin applied aspart of the splicing 

process. Columbia Forest Products reports the annual use of about 45,000 Ibs of 

splicing resin with a VOC content of 0.35% by weight. The splicing resin also 

contains formaldehyde, a hazardous air pollutant (HAP), at about the same weight 

percent. Assuming 100% of the volatile components and hazardous pollutants in 

the resin are emitted, actual VOC and HAP emissions from resin application are 

each less than 1 ton/year. Columbia Forest Products shall limit VOC and HAP 

emissions from the Splicing Process to 2.0 tons/year. 

I. Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed 20 percent opacity, except for no more than five 

minutes in any 1-hour period. Compliance shall be determined by an aggregate of 

the individual 15-second opacity observations which exceed 20 percent in any one 

hour. 

J. VOC RACT 

Columbia Forest Products does not emit VOCs from non-exempt equipment 

greater than 40 tons per calendar year and is therefore not subject to Chapter 134 

(Reasonably Available Control Technology for Facilities that Emit Volatile 

Organic Compounds) of the Department's Regulations. 

K. Annual Emissions 

Annual emissions were calculated based on the following: 

Columbia Forest Products shall be restricted to firing no more than 1,250,000 

gallons of#2 fuel oil in Boiler #3 and 250,000 gallons of#2 fuel oil in Veneer 

Dryer #1; the fuel oil having a sulfur content of 0.35% by weight, both based 

on a ten-period rolling total. 

Columbia Forest Products shall be restricted to firing no more than 10,000 

tons of wood in Boilers #1 and #2, 15,000 tons of wood in Boiler #3, and 

8,760 tons of wood in Veneer Dryer #1, all based on a ten-period rolling total. 

Columbia Forest Products shall be restricted from firing any wood fuel in 

Veneer Dryer #1 unless and until Stack #V1 is raised to a height of 65 feet 

above ground level. 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

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Departmental 

Findings of Fact and Order 

Air Emission License 

Total Annual Licensed Emissions for the Facility (Annual licensed emissions are used to calculate license fees) 

Pollutant 

Fuel 

combusted 

PM 

PM•0 

SO2 

NOx 

Emissions in Tons/Year 

CO 

VOC 

HAPs 

Boilers Energex Veneer 

#1 & #2 Boiler #3 (Dryer #1) Dryers 

wood Wood Oil wood oil 

24.3 11.5 8.8 6.7 1.4 52.7 

14.4 7.0 8.8 3.9 1.4 35.5 

1.1 1.7 43.8 1.0 9.8 57.4 

22.1 33.1 1.8 19.3 2.5 78.8 

27.0 27.3 3.1 23.7 0.6 81.7 

1.8 2.6 0.2 1.5 0.1 30.6 2.0 38.8 

2.0 2.0 

Glue Total 

Columbia Forest Products shall not exceed 2.0 tons/year of HAP from the use of resin 

in the Splicing Process. 

III.AMBIENT AIR QUALITY ANALYSIS 

A. Overview 

A combination of screening and refined modeling was performed to show that 

emissions from CFP, in conjunction with other sources, would not cause or 

contribute, to violations of Maine Ambient Air Quality Standards (MAAQS) for 

SO2, PMl0, NOz and CO or to Class II increments for PM•0 and NO2. It was 

determined that Columbia Forest Products does not consume SO• increment, therefore a Class II SO2 increment analysis was not performed. 

Since no modification is associated with this licensing action, MEDEP has 

determined that an assessment of Class I Air Quality Related Values (AQRVs) is 

not required for CFP. 

B. Model Inputs 

The ISC-PRIME model was used in refined simple terrain mode to address 

standards in all areas, including the cavity region. In addition, the COMPLEX-I 

VALLEY (CI-VM) model was used to evaluate impacts in intermediate and 

complex terrain, i.e., areas where terrain elevations exceed stack-top elevations. 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

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12 

Departmental 

Findings of Fact and Order 

Air Emission License 

All modeling was performed in accordance with all applicable requirements of the 

Maine Department of Environmental Protection, Bureau of Air Quality (MEDEPBAQ) and the United States Environmental Protection Agency (USEPA). 

A valid 5-year hourly meteorological off-site database was used for the refined 

modeling. The wind data was collected at a height of 10.00 meters at the Caribou 

National Weather Service station meteorological site during the 5-year period 

1985-1989. Missing data were interpolated or coded as missing. Surface data 

collected at Loring Air Force Base were substituted for missing data. Hourly 

cloud cover, ceiling height and surface wind speed from Caribou NWS station 

were used to calculate stability. Hourly mixing heights were derived from surface 

and upper air data collected at Caribou NWS station. 

Modeling stack parameters for CFP and other nearby sources are listed in Table 

III-1. The ISC-PRIME modeling analysis accounted for the potential of building 

wake effects on emissions from all modeled stacks that are below their respective 

formula GEP stack heights. 

Table III-1: Stack Parameters 

Facility/Stack 

Stack GEP UTM UTM 

Base Stack Stack Stack Easting Northing 

Elevation Height Height Diameter NAD27 NAD27 

Columbia Forest Products 

Stack 161.54 19.81 32.20 0.86 573.421 5172.828 

Stack 2 161.54 19.81 32.20 0.86 573.426 5172.831 

Stack 3 161.54 19.81 32.20 0.76 573.417 5172.859 

Stack V1 161.54 8.72 32.20 0.90 573.463 5172.775 

Tatermeal 

Stack (Dryers 1, 2 & 3) 144.78 30.48 31.24 1.83 573.471 5171.334 

Columbia Forest Products 

Stack 161.54 

Stack 2 161.54 

Stack 3 161.54 

Stack V1 161.54 

19.81 32.20 

19.81 32.20 

19.81 32.20 

8.72 32.20 

0.86 573.421 5172.828 

0.86 573.426 5172.831 

0.76 573.417 5172.859 

0.90 573.463 5172.775 

Tatermeal 

Stack (Dryer 3 only) l 144.78 30.48 31.24 1.83 573.455 5171.317 

Columbia ForestProducts 

Stack 161.54 19.81 32.20 0.86 573.421 5172.828 

Stack2 161.54 19.81 32.20 0.86 573.426 5172.831 

Stack 3 161.54 7.90 32.20 0.79 573.427 5172.763 

Stack 4 161.54 7.90 32.20 0.49 573.428 5172.76i 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

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13 

Departmental 

Findings of Fact and Order 

Air Emission License 

Emission parameters for CFP and other nearby sources for MAAQS and 

increment modeling are listed in Table 111-2. Emission parameters for CFP are 

based on the maximum license allowed operating configuration. For the purpose 

of determining NO 2 and PM10 impacts, all NO× and PM emissions were 

conservatively assumed to convert to NO 2 and PMl0 respectively. 

Two maximum operating scenarios were included in CFP modeling analysis: 

1. Boilers #1 and #2 firing wood; Boiler #3 and Veneer Dryer 

firing oil, 

2. Boilers #1, #2, #3 firing wood; Veneer Dryer firing oil 

This modeling analysis did not account for the option to burn wood'in the veneer 

dryer at the current stack height. A previous ambient air quality analysis showed 

that that Veneer Dryer #1 would not meet Maine Ambient Air Quality Standards 

during periods of wood firing unless the stack height was raised tol 9.81 meters. 

Table 111-2: Emission Parameters 

Facility/Stack Averaging SO2 PMI0 

Period(s) ,(g/s) (g/s) 

Columbia Forest Products 

Stack All 0.05 0.61 

Stack 2 All 0.05 0.61 

Stack 3 (oil) All 1.86 0.37 

Stack 3 (wood) All 0.08 0.30 

Stack V All 1.06 0.15 

Tatermeal 

Stack All 22.95 5.77 

Columbia Forest Products 

Stack 

Stack 2 

Stack 3 (oil) 

Stack 3 (wood) 

Stack V1 (oil) 

Stack V! (wood) 

Tatermeal 

Stack 

Stack Stack 

NO2 CO Temp Velocity 

!•/•),1 (•(s) •).. 

0.93 1.13 560.93 4.34 

0.93 1.13 560.93 4.34 

0.52 0.13 560.93 9.23 

1.48 1.21 560.93 8.89 

0.27 0.08 435.90 12.31 

li!i 6.20 4.75 423.15 24.75 

All i::•:••i;!•i:!5 0.14 0.22 •;•'•;•:•:••' 560.93 

All 0.14 0.22 

All 0.13 0.66 560.93 

All 0.30 1.48 560.93 

All 0.02 0.03 • 435.90 

All 0.12 0.60 435.90 

1.05 

1.05 

8.89 

8.89 

37.35 

37.35 

0.74 3.50 415.93[ 18.58 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

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Table III-2: Emission Parameters contimued 

Columbia Forest Products 

Stack 1 Annual 

Stack 2 Annual 

Stack 3 Annual 

Columbia Forest Products 

Stack All 

Stack 2 All 

Stack 3 All 

Stack 4 All 

0.23 i.i:i :.•i; i:: •.i• 560.93 

0.23 i•!.i;i:.i-) i•i!::i:iil. 560.93 

0.03 350.00 

0.02 • 350.00 

1.72 

1.72 

0.71 

1.30 

C. Single Source Modeling Impacts 

SCREEN3 modeling was previously performed for CFP for the maximum, 

typical, and minimum operating load cases for Columbia Forest Products alone. 

The highest impact for each• stack, independent of receptor location, was added 

together for each scenario to conservatively determine facility-wide impacts. It 

was demonstrated that the maximum operating load case for the boilers would 

result in maximum impacts in simple, intermediate, and complex terrain. ISCPRIME simple terrain refined modeling, using five years of meteorological data, 

and CI-VM screening modeling was then performed for CFP's maximum load 

case. 

The modeling results for CFP alone, in simple and complex terrain, are shown in 

Tables Ill-3 and 111-4 respectively. All SO2, PMa0 and NO 2 averaging period 

impacts were significant in both modeling analyses. It was demonstrated that 

CFP would have no significant impacts for all CO averaging periods in simple 

and complex terrain; thus, no further analysis was required for these 

pollutant/terrain combinations. Pollutant averaging periods where the respective 

maximum predicted impact exceeded the respective significance level are 

indicated in boldface type. 

Table III-3: Maximum ISC-PRIME Predicted Impacts from CFP Alone 

Pollutant 

SO2 

Averaging 

Period 

Max 

Impact 

Qtg/m 3) 

258.73 

Annual 

Receptor 

UTM E 

(km) 

573.171 

Receptor 

UTM N 

(km) 

5173.278, 

Receptor 

Elevation 

(m) 

3-hour 179.83 

24-h0ur 177.12 573.420 5172.722 161.54 5 

40.78 573.470 5172.782 161.54 1 

Class II 

Significanc e 

Level 

(•t•/m 3) 

25 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

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Table III-3: Maximum ISC-PRIME Predicted Impacts from CFP Alone continued 

PM•0 24-hour 103.49 573.460 

Annuhl 14.023 573.470 

NO2. Annual 22.82 573.470 

CO 1-hour 546.53 573.071 

8-hour 242.03 573.460 

5172.652 161.54 

5172.782 161.54 

5172.782 161.54 

5173.278 179.83 

5172.652 

2000 

161.54 500 

Table III-4: Maximum CI-VM Predicted Impacts from CFP Alone 

Pollutant 

SO2 

PMlo 

NO2 

CO 

Averaging 

Period 

3-hour 

24-hour 

Annual 

24-hour 

Annual 

Annual 

1-hour 

8-hour 

Max 

Impact. 

(•tg/m 3) 

97.41 

27.06 

8.66 

25.97 

8.31 

10.88 

142.25 

99.57 

Receptor 

UTM E 

(km) 

572.571 

572.571 

572.57! 

572.571 

572.571 

572.571 

572.571 

572.571 

Receptor 

UTM N 

(km) 

5173.478 

5173.478 

5173.478 

5173.378 

5173.378 

5173.378 

5173.378 

5173.378 

Receptor 

Elevation 

(m) 

204.22 

204.22 

204.22 

201.17 

201.17 

201.17 

201.17 

Class II 

Significance 

Level 

(btg/m 3) 

25 

5 

1 

1 

2000 

201.17 500 

D. Combined Source Modeling Impacts 

Because modeled impacts from CFP alone were greater than significance levels 

for all SO2, NO2 and PM10 averaging periods, other sources not explicitly included in the modeling analysis must be included by using representative background concentrations for the area. Northern Maine rural background concentrations derived from representative sites are listed in Table 11I-5. 

TABLE III-5: Background Concentrations (•tg/m 3) 

Pollutant Averaging Background Date 

Period Concentration 

SO2 3-hour 24 2003 

24-hour 13 

Annual 5 

PMl0 24-hour 32 2003 

Annual 10 

NO2 Annual 11 19952 

Notes: 

Robinson site, Easton 

TLSP site, Cape Elizabeth 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

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MEDEP-BAQ identified other sources whose impacts would potentially be 

significant in CFP's significant impact area. Only one other source was explicitly 

included in the modeling: Tatermeal (Presque Isle). 

Table 111-6 summarizes the maximum combined source impacts. The predicted 

impacts are added to conservative background concentrations to obtain the final 

predicted impact. 

All combined source SO2, PM10 and NO 2 averaging period impacts were below 

their respective MAAQS. Because the impacts using this method meet MAAQS, 

no furth.er MAAQS modeling for CFP need be performed. 

Table III-6: ISC-PRIME/CI-VM Maximum Combined Source Impacts 

Eo 

Pollutant Averaging 

Period 

SO2 3-hour 

24-hour 

Annual 

PM10 24-hour 

Annual 

NO2 Annual 

ISCPRIME/ Receptor 

CI-VM UTM-E 

Max (km) 

258.73* 573.171 

177.12" 573.420 

42.11" 573.470 

103.49" 573.460 

14.28" 573.470 

23.09* 573.470 

Key: * ISC3 Result, 

Receptor Receptor 

UTM-N Elevation 

(km) (m) 

5173.278 179.83 

5172.722 161.54 

5172.782 161.54 

5172.652 161.54 

5172.782 161.54 

5172.782 161.54 

** CI-VMResult 

Background 

(•tg/m 3) 

Max 

Total 

Impact 

(gg/m 3) 

MAAQS 

(gg/m •) 

24 282.73 1150 

13 190.12 230 

5 57 

32 

47.11 

135.49 

24.28 

35.09 

Increment 

10 

11 

CFP maximum increment impacts were predicted using ISC-PRIME refined 

modeling in simple terrain and CI-VM in complex terrain. For addressing 

increment impacts in intermediate terrain (i.e., terrain above stack top and below 

plume centerline), the ISC-PRIME and CI-VM were run individually, and the 

higher of the two increment impacts chosen. 

Results of the single and combined source PM•0 and NO 2 increment analyses are 

shown in Tables III-7 and Table III-8, respectively. All CFP alone and combined 

source modeled increment impacts were below all increment standards. Because 

the predicted increment impacts meet increment standards, no further increment 

modeling for CFP needed to be performed. 

150 

4O 

100 
Columbia Forest Produ cts 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

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Table III-7: Increment Consumption in Class II Areas from CFP Alone 

Pollutant 

PM1o 

NO2 

Averaging 

Period 

24-hour 

Annual 

Annual 

Key: * ISC3 Result, 

Max Receptor 

Impact UTM-E 

(•,•[/m 3) (km) 

12.10" 573.420 

0.38* 573.371 

16.85" 573.470 

Receptor 

UTM-N 

(km) 

5172.722 

5173.478 

5172.772 

** CI-VM Result 

Receptor 

Elevation 

(m) 

161.54 

179.83 

161,54 

Class II 

Increment 

30 

17 

25 

Table III-8: Combined Source Class II Increment Consumption 

Pollutant 

PMt0 

NO2 

Averaging 

Period 

24-hour 

Annual 

Max 

Impact 

(p•/m •) 

12.10" 

0.55* 573.371 

Annual 17.84" 

Key: ISC3 Result, ** CI-VM Result 

Receptor Receptor 

UTM-E UTM-N 

(km) (km) 

573.420 5172.722 

5173.478 

573.470 5172.762 

Receptor 

Elevation 

(m) 

161.54 

179.83 

161.54 

Class II 

Increment 

(l•glm •) 

30 

17 

Federal guidance and Chapter 140 of the DEP regulations require that any major 

new source or any source undergoing a major modification provide additional 

analyses of impacts that would occur as a direct result of the general, commercial, residential, industrial and mobile-source growth associated with the construction 

and operation of that source. Since no modification is associated with this 

licensing action, no additional analyses were required. 

F. Class I Impacts 

Since no modification is associated with this licensing action, MEDEP has 

determined that an assessment of Class I Air Quality Related Values (AQRVs) is 

not required. 

G. Summary 

In summary, it has been demonstrated that CFP in its current configuration will 

not cause or contribute to a violation of any SO2, PM10 NO 2 or CO averaging 

period MAAQS. It has also been demonstrated that CFP will not cause or 

contribute to a violation of any PM 10 or NO 2 averaging period Class II increment 

standards. 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

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Findings of Fact and Order 

Air Emission License 

Should CFP ever opt to burn wood in the veneer dryer, the veneer dryer stack is 

required to be increased from 8.72 meters (current height) to a new height of 

19.81 meters. This stack height increase is based upon the results of a refined 

modeling anlysis completed by MEDEP-BAQ in April, 2003. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-353-71-H-R subject to the 

following conditions: 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(38 MRSA §347-C). 

(2) The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [MEDEP Chapter 115] 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [MEDEP Chapter 115] 

(4) The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. [MEDEP Chapter 115] 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

(5) 

(6) 

(7) 

(8) 

(9) 

) 

) 

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Findings of Fact and Order 

Air Emission License 

(10) 

The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. § 353. [MEDEP Chapter 115] 

(11) 

The license does not convey any property rights of any sort, or any exclusive 

privilege. [MEDEP Chapter 115] 

The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. [MEDEP Chapter 115] 

The licensee shall maintain sufficient records to accurately document compliance with emission standards and license conditions and shall maintain such records 

for a minimum of Six (6) years. The records shall be submitted to the Department 

upon written request. [MEDEP Chapter 115] 

The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [MEDEP Chapter 115] 

The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 

In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuant to any other requirement of this license to perfbrm stack testing. 

install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

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Findings of Fact and Order 

Air Emission License 

submit a written report to the Department within thirty (30) days from date of 

test completion. 

[MEDEP Chapter 115] 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

Ao within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 

the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

[MEDEP Chapter 115] 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated o•" is in violation of any 

statute, regulation, or Part 70 license requirement. [MEDEP Chapter 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 115] 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

) 

21 

Departmental 

Findings of Fact an d Order 

Air Emission License 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably require to determine the licensee's compliance status. [MEDEP Chapter 115] 

SPECIFIC CONDITIONS 

(16) Boilers #1 & #2 

A. Total annual fuel use for Boilers #1 and #2 shall not exceed 10,000 tons of 

wood on a twelve-month rolling total basis. To demonstrate compliance with 

the fuel cap, Columbia Forest Products shall maintain a fuel use record for the 

wood fired in the two boilers. The fuel use record shall be maintained on a 

ten-period rolling total basis. [MEDEP Chapter 115, BPT] 

B. Emissions shall not exceed the following: 

(17) 

Equipment 

Boiler #1 

Boiler #2 

[MEDEP, Chapter 103, Section 2(A)(3)(a), MEDEP Chapter I 1 

PM PM10 SO2 NOx 

lb/MMBtu 0.54 

lb/hr 8.1 4.8 0.4 7.4 •9.0 0.6 

lb/MMBtu 0.54 • 

lb/hr 8.1 4.8 0.4 7.4 .9.0 0.6 

5, BPT] 

VOC 

Co Visible emissions from Stacks #1 and #2 each shall not exceed 30% opacity 

on a 6-minute block average, except for no more than two 6-minute block 

averages in a continuous 3-hour period. [MEDEP Chapter 101 

Boiler #3 

Total annual fuel use for Boiler #3 shall not exceed 1,250,000 gallons of #2 

fuel oil with a maximum sulfur content of 0.35% sulfur by weight, on a 

twelve-month rolling total basis. Compliance shall be demonstrated by fuel 

records from the supplier showing the quantity of fuel delivered and the 

percent sulfur of the fuel. The fuel use record shall be maintained on a 

ten-period foiling total basis. [MEDEP Chapter 115, BPT] 

Bo Total annual fuel use for Boiler #3 shall not exceed 15,000 tons of wood on a 

twelve-month rolling total basis. To demonstrate compliance with the fuel 

restrictions, Columbia Forest Products shall maintain a fuel use record for the 

wood fired in Boiler #3. The fuel use record shall be maintained on a 

ten-period rolling total basis. [MEDEP Chapter 115, BPT] 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

) 

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Findings of Fact and Order 

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C. Emissions shall not exceed the following: 

Equipment 

Boiler #3 

(Firing Oil) 

(F'n'il• Wood) 

PM PM10 

lb/MMBtu 0.1 

lb/hr 2.9 2.9 

lb/MMBtu 0.17 

lb/hr 4.1 2.5 

SO2 NOx 

14.7 4.2 

0.6 11.8 

CO VOC 

9.7),• 0.1 

1.3 0.9 

[MEDEP Chapter 115, BPT] 

D. Boilers #3 is subject to Federal New Source Performance Standards, Subpart 

Dc. Columbia Forest Products shall comply with all requirements of 40 CFR 

Part 60, Subpart Dc including, but not limited to, the following: 

Columbia Forest Products shall record and maintain records of the 

amounts of ea6h fuel combusted during each day and the sulfur content of 

the combusted fuel. 

Columbia Forest Products shall submit to EPA and the Department 

semi-annual reports. These reports shall include the calendar dates 

covered in the reporting period and records of fuel supplier certifications. 

The semi-annual reports are due within 30 days of the end of each 

6-month period. 

3. The following address for EPA shall be used for any reports or 

notifications required to be copied to them: 

Compliance Clerk 

USEPA Region 1 

Congress Street 

Suite 1100 

Boston, MA 02114-2023 

Eo Visible emissions from Stack #B3 during periods of. wood combustion or 

during periods of combusting wood and oil in combination shall not exceed 

30% opacity on a 6-minute block average, except for no more than two 

6-minute block averages in a 3-hour period. [MEDEP Chapter 101 

Fo Visible emissions from Stack #B3 during periods of oil combustion only shall 

not exceed 20% opacity on a 6-minute block average, except for no more than 

two 6-minute block averages in a 3-hour period. [MEDEP Chapter 101 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

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Findings of Fact and Order 

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(18) Veneer Dryer #1 

Total annual fuel use for Veneer Dryer #1 's fuel-fired Proctor Dryer (Heaters 

#1, #2 & #3) shall not exceed 250,000 gallons of #2 fuel oil with a maximum 

sulfur content of 0.35%, on a 12-month rolling total basis. Compliance shall 

be demonstrated by fuel records from the supplier showing the quantity of fuel 

delivered and the percent sulfur of the fuel. The fuel use record shall be 

maintained.on a ten-period rolling total basis. [MEDEP Chapter 115, BPT] 

Bo Total annual fuel use for Veneer Dryer #1 's Energex Combustion Unit shall 

not exceed 8,760 tons of wood on a twelve-month rolling total basis. To 

demonstrate compliance with the fuel cap, Columbia Forest Products shall 

maintain a fuel use record for the wood fired in Veneer Dryer #1. The fuel 

use record shall be maintained on a ten-period rolling total basis. 

[MEDEP Chapter 115, BPT] 

Columbia Forest Products shall be restricted from firing any wood fuel in 

Veneer Dryer #1 unless and until Stack #V1 is raised to a height of 65 feet 

above ground level and documentation has been provided to the Department 

indicating that the Veneer Dryer's stack has been extended. 

[MEDEP Chapter 115, BPT] 

D. Emissions shall not exceed the following: 

Equipment PM PMlo S02 

Heaters.# 1, lb/MMBtu 0.1 

#2 and #3 lb/hr 1.2 1.2 

lb/MMBtu 0.17 

NOx 

8.4 2.1 

0.1 

Wood Firing lb/hr 4.6 2.7 0.7 13.2 

[MEDEP, Chapter 103, Section 2(A)(B)(1), MEDEP Chapter 115, BPT 

CO VOC 

0.5 0.1 

16.2 1.6 

Visible emissions from Veneer Dryer #1 during periods of wood firing shall 

not exceed 30% opacity on a 6-minute block average, except for two 6-minute 

block averages in a 3-hour period. [MEDEP Chapter 101] 

Visible emissions from Veneer Dryer #1 during periods of oil firing shall not 

exceed 20% opacity on a 6-minute block average, except for two 6-minute 

block averages in a 3-hour period. [MEDEP Chapter 101] 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

) 

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Findings of Fact and Order 

Air Emission License 

(19) Veneer Drying Process 

A. Columbia Forest Products shall be restricted to the following VOC emissions 

from the drying of hardwood veneer in Veneer Dryers #1, #2, and #3: 

Equipment 

Veneer Dryer #1 3 

VOC Emissions 

Pounds per hour (lb/hr) Tons per year (tons/yr) 

13.1 

Veneer Dryer #2 I 

Veneer Dryer #3 3 

4.4 

13.1 

Columbia Forest Products shall maintain process VOC emission records for 

the facility's veneer drying units. VOC emission calculations shall be based 

on an emission factor of 0.0234. pounds of VOC per 1,000 square feet of 

veneer dried, and the square footage of veneer actually dried. The Department 

may approve the use of an alternative emission factor if additional testing 

leads to the generation of a more appropriate emission factor. VOC emission 

records shall be maintained on a drying cycle and ten-period rolling total 

basis. [MEDEP Chapter 115, BPT] 

(20) Splicing Process 

A. Columbia Forest Products shall not exceed 2.0 tons/year of VOC from the 

Re-splicing Process. [MEDEP Chapter 115, BPT] 

B. Columbia Forest Products shall not exceed 2.0 tons/year of HAP from the 

Re-splicing Process. [MEDEP Chapter 115, BPT] 

Co Columbia Forest Products shall maintain process VOC and HAP emission 

records for the Re-Splicing Process. VOC and HAP emission calculations 

from the Re-Splicing Process shall be based on the VOC and HAP weight 

percentages from the MSDS sheet and the amount of re-splicing resin used. 

Emission records from the Re-Splicing Process shall be maintained on a 

ten-period rolling total basis. 

[MEDEP Chapter 115, BPT] 

(21) Wood Handling 

A. Columbia Forest Products shall establish a system of maintenance, inspection 

and repair for the wood dust handling system, which shall allow for a monthly 

inspection of the system and Columbia Forest Products shall document 

compliance by means of a maintenance, inspection and repair log. 

[MEDEP Chapter 115, BPT] 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

) 

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Findings of Fact and Order 

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B. Columbia Forest Products shall operate and maintain the cyclones in a manner 

that minimizes emissions from the cyclones. [MEDEP Chapter 115, BPT] 

Visible emissions from the wood fuel handling equipment (including 

Cyclones #1, #2 and #3 and the wood fuel conveyor system) shall not exceed 

20% opacity on a 6-minute block average basis, except for no more than one 

6-minute block average in a 1-hour period. 

[MEDEP Chapter 101, MEDEP Chapter 115, BPT] 

(22) Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed 20% opacity, except for no more than five minutes in 

any 1-hour period. Compliance shall be determined by an aggregate of the 

individual 15-second opacity observations which exceed 20% in any l-hour. 

IMEDEP Chapter 101 

(23) Columbia Forest Products shall notify the Department within 48 hours and submit 

a report •o the Department on a quarterly basis if a malfunction or breakdown in 

any component causes a violation of any emission standard (38 MRSA §605). 

(24) Annual Emission Statement 

In accordance with MEDEP Chapter 137, the licensee shall annually report to the 

Department the information necessary to accurately update the State's emission 

inventory by means of: 

1) A computer program and accompanying instructions Supplied by the 

Department; 

or 

2) A written emission statement containing the information required in 

MEDEP Chapter 137. 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 

The emission statement must be submitted as specified in Chapter 137. 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

) 

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Departmental 

Findings of Fact and Order 

Air Emission License 

(25) Air Toxics Emission Statement 

If Columbia Forest Products exceeds the thresholds for HAPs listed in 

Appendix A of MEDEP Chapter 137 in an inventory year, in accordance with 

MEDEP Chapter 137 the licensee shall report, no later than July every three 

years (2005, 2008, 2011, etc.) or as otherwise stated in Chapter 137, the 

information necessary to accurately update the State's toxic air pollutants 

emission inventory by means of a computer program supplied by the Department 

or a written emission statement containing the information required in MEDEP 

Chapter 137. 

NOTE: Based on emission factors developed by the Eastern Research Group 

(ERG) in their memo "Development of Average Emission Factors and Baseline 

Emission Estimates for the Industrial, Commercial and Institutional Boilers and 

Process Heaters National Emission Standard for Hazardous Air Pollutants" dated 

October 2002, Columbia Forest Products will most likely exceed the Chapter 137 

thresholds of HAPs based on fuel burning alone should the facility exceed the 

following firing rates in a calendar year: 

Control 

Fuel Device 

Wood/Biomass C•,clone 

#2 Fuel Oil No Control 

Quantity of fuel before Chapter 137 

toxics reporting threshold is exceeded 

1,403 Tons 

661,376 Gallons 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 [MEDEP Chapter 137] 

(26) Columbia Forest Products shall notify the Department within 48 hours and submit 

a report to the Department on a quarterly basis if a malfunction or breakdown in 

any component causes a violation of any emission standard 

(Title 38 MRSA §605-C). 
Columbia Forest Products 

Aroostook County 

Presque Isle, Maine 

A-353-71-H-R (SM) 

) 

) 

) 

27 

Departmental 

Findings of Fact and Order 

Air Emission License 

(27) Payment of Annual License Fee 

Columbia Forest Products shall pay the annual air emission license fee within 30 

days of December 31 of each year. Pursuant to 38 MRSA §353-A, failure to pay 

this annual fee in the stated timeframe is sufficient grounds for revocation of the 

license under 38 MRSA §341-D, subsection 3. 

DONE AND DATED/N AUGUSTA, MAINE THIS DAY OF 2006. 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

BY: 

DAVID P. LITTELL, COMMISSIONER 

The term of this license shall be five (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: April 8• 2005 

Date of application acceptance: April 13• 2005 

Date filed with the Board of Environmental Protection: 

This Order prepared by, Peter G. Carleton, Bureau Of Air Quality 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license application, staff investigation reports and other 

documents in the applicant's file in the Bureau of Air Quality; pursuant to 38 M.R.S.A., 

Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

Introduction 

Sonoco Products Co. (Sonoco) of North Anson, Maine has applied to renew their 

Air Emission License permitting the operation of emission sources associated 

with their wood cable reels manufacturing facility. 

B. Emission Equipment 

Sonoco is licensed to operate the following equipment: 

Fuel Burning Equipment 

Equipment 

Boiler 

Boiler #2 

Emergency 

Generator* 

Maximum 

Capacity 

(MMBtu/hr) 

27 

20 

1.22 

*This equipment not previousl, 

Maximum 

Firing Rate 

3 ton/hr 

133 gal/hr 

8.9 gal/hr 

•licensed. 

Fuel Type, 

% sulfur 

sawdust/bark 

#6 fuel oil, 0.5% 

diesel fuel, 0.05 

Control 

Equipment 

Cyclone 

none 

none 

2 

3 

Process Equipment 

Equipment 

Spray Paint Booths 

Kilns 

Finger Joining 

Operation 

Regulated 

Pollutant 

VOC & PM 

VOC 

VOC 

Sonoco also has two parts washers used for maintenance activities. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Sonoco had previously licensed the operation of wood handling equipment 

associated with their sawmill operations. Sonoco indicated in a letter to the 

Department dated March 12, 2001 that they were buying all of their lumber and 

no longer producing any on site. All sawmill equipment on site is being removed 

and sold. 

C. Application Classification 

This license is considered to be a renewal of current licensed emission units. 

II. BEST PRACTICAL TREATMENT (BPT) 

mo Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Air Regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for existing emissions equipment means that method which controls or 

reduces emissions to the lowest possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emission 

from the source being considered; and 

the economic feasibility for the type of establishment involved. 

BPT for new sources and modifications requires a demonstration that emissions 

are receiving Best Available Control Technology (BACT), as defined in Chapter 

100 of the Air Regulations. BACq • is a top-down approach to selecting air 

emission controls considering economic, environmental and energy impacts. 

No Boiler #1 

Sonoco operates Boilers #1 and #2 for facility heating and process heat for the 

kilns and paint booths. Boiler #1 fires wood waste. PM emissions from Boiler #1 

are controlled by a cyclone. 

Boiler #1 was installed prior to1989 and is therefore not subject to the New 

Source Performance Standards (NSPS) Subpart Dc for steam generating units 

greater than 10 MMBtu/hr manufactured after June 9, 1989. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Do 

A summary of.the BPT analysis for Boiler #1 (27 MMBtu/hr) is the following: 

1. The total fuel use for Boiler #1 shall not exceed 25,000 tons/year of wood 

waste at 50% moisture or equivalent, based on a 12 month rolling total. 

2. Sonoco shall be limited to operating only Boiler #1 or Boiler #2 at any given time except for periods of start-up and shut-down. 

3. Chapter 103 regulates PM emission limits. The PM10 limits are derived from 

the PM limits. 

4. Sonoco shall continuously use the cyclone to control particulate matter when 

operating Boiler #1. 

5. SO2, NOx, CO, and VOC limits are based on a previous modeling analysis. 6. Visible emissions from Boiler #1 shall not exceed 30% opacity on a 6 minute 

block average, except for no more than 2 six minute block averages in a 

continuous 3 hour period. 

Boiler #2 

Boiler #2 is used on days when there is a low heat demand in the mill and as a 

back up for Boiler #1. Boiler #2 fires #6 fuel oil. 

Boiler #2 was installed prior to1989 and is therefore not subject to the New 

Source Performance Standards (NSPS) Subpart Dc for steam generating units 

greater than 10 MMBtu/hr manufactured after June 9, 1989. 

1. The total fuel use for Boiler #2 shall not exceed 50,000 gal/year of#6 fuel oil, based on a 12 month rolling total, with a maximum sulfur content not to 

exceed 0.5% by weight. 

2. Sonoco shall be limited to operating only Boiler #1 or Boiler #2 at any given time except for periods of start-up and shut-down. 

3. Chapter 106 regulates fuel sulfur content, however in this case BPT for SO2 

was determined to be a more stringent limit of 0.5% and shall be used. 

4. Chapter 103 regulates PM emission limits. The PM•0 limits are derived from 

the PM limits. 

5. NOx, CO, and VOC limits are based on a previous modeling analysis. 6. Visible emissions from Boiler #2 shall not exceed 30% opacity on a 6 minute 

block average, except for no more than 2 six minute block averages in a 

continuous 3 hour period. 

Emergency Generator 

Sonoco operates a back up emergency diesel generator. A summary of the BACT 

analysis for the Emergency Generator (125 kW/1.22 MMBtu/hr) is the following: 

1. The Emergency Generator shall fire only diesel fuel with a maximum sulfur 

content not to exceed 0.05% by weight. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

2. The Emergency Generator shall be limited to 500 hr/yr of operation based on 

a 12 month rolling total. Compliance shall be demonstrated by a written log 

of all generator operating hours. 

3. Chapter 106 regulates fuel sulfur content, however in this case BACT for SO2 

was determined to be a more stringent limit of 0.05% and shall be used. 

4. The PM and PM•0 limits are derived from Chapter 103. 

5. NOx, CO, and VOC emission limits are based upon AP-42 data dated 10/96. 

6. Visible emissions from the Emergency Generator shall not exceed 30% 

opacity on a 6 minute block average, except for no more than 2 six minute 

block averages in a continuous 3 hour period. 

Kilns 

Sonoco operates two kilns for drying lumber. Heat for the kilns is provided by 

either Boiler #1 or Boiler #2. A summary of BPT for the &ying kilns is the 

following: 

1. Sonoco shall not exceed a yearly throughput in the kilns of 5 million board 

feet per year based on a 12 month rolling total. 

2. Sonoco shall keep monthly records of board feet processed. 

Paint Booths 

Sonoco operates two spray paint booths for painting the wooden reels. The 

average VOC content of the paint used is 2.36 lbs VOC per gallon of paint. A 

summary of BPT for the paint booths is the following: 

1. Sonoco shall be limited to 3,500 gallons per year of paint, based on a 12 

month rolling total. 

2. Sonoco shall maintain monthly records indicating the amount of paint 

received and the VOC content of the paint. 

3. Sonoco shall install and maintain particulate filters in the spray booths. 

4. Visible emissions from the paint booths shall not exceed 5% opacity on a 6 

minute block average basis. 

G. Finger Joining Process 

Sonoco operates a finger joining operation in order to reduce waste by reclaiming 

smaller lengths of wood. A summary of BPT for the finger joining operation is 

the following: 

Sonoco shall not exceed a limit of 4.6 tons VOC per year from the finger 

joining operation, based on a 12 month rolling total. Compliance shall be 

demonstrated by monthly records indicating the amount of glue used and its 

VOC content. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 5 

Departmental 

Findings of Fact and Order 

Air Emission License 

H. Parts Washers 

Sonoco shall keep records of the amount of any type of solvent added to the 

degreaser units. 

Annual Emission Restrictions 

Sonoco shall be restricted to the following annual emissions, based on a 12 month 

rolling total: 

Total Allowable Annual Emission for the Facility 

(used to calculate the annual license fee) 

Pollutant 

PM 

PMlo 

Tons/Year 

53.7 

53.7 

SO2 4.2 

NOx 22.4 

CO 

VOC 

82.6 

16.8 

III.AMBIENT AIR QUALITY ANALYSIS 

Sonoco previously submitted an ambient air quality analysis demonstrating that 

emissions from the facility, in conjunction with all other sources, do not violate ambient 

air quality standards. An additional ambient air quality analysis is not required for this 

renewal. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I,R 

Departmental 

Findings of Fact and Order 

Air Emission License 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-130-71-I-R subject to the 

following conditions: 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions. 

(2) The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more, The 

Department may extend this time period upon a Satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. 

(4) The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. 

(5) The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. •. 353. 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent, with good air 

pollution control practice for minimizing emissions. 

(8) The licensee shall maintain sufficient records to accurately document compliance with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. 

(9) The licensee Shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. 

(10) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

(i) perform stack testing to demonstrate compliance with the applicable emission standards under circumstances representative of the facility's normal process and operating conditions: 

a. within sixty (60) calendar days of receipt of a notification to test 

from the Department or EPA, if visible emissions, equipment operating parameters, staff inspection, air monitoring or other 

Cause indicate to the Department that equipment may be operating 

out of compliance .with emission standards or license conditions; or 

b. pursuant to any other requirement of this license to perform stack 

testing. 

(ii) install or make provisions to install test ports that meet the criteria of 40 

CFR Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

(iii) submit a written report to the Department within thirty (30) days from date 

of test completion. 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

(i) within thirty (30) days following receipt of such test results, the licensee 

shall re-test the non-complying emission source under circumstances 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(ii) 

(iii) 

representative of the facility's normal process and operating conditions 

and in accordance with the Department's air emission compliance test 

protocol and 40 CFR Part 60 or other method approved or required by the 

Department; and 

the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is 

demonstrated under normal and representative process and operating 

conditions, except to the extent that the facility can prove to the 

satisfaction of the Department that there were intervening days during 

which no violation occurred or that the violation was not continuing in 

nature; and 

the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, 

operate under such alternative load conditions on an interim basis prior to 

a demonstration of compliance under normal and representative process 

and operating conditions. 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

bythe EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. 

(14) 

(15) 

The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. 

(16) Boiler #1 

A. Fuel use shall not exceed 25,000 tordyr of wood waste at 50% moisture or 

equivalent (12 month rolling total). Fuel records, including amount of fuel 

fired shall be maintained on a monthly basis, in addition to the 12 month 

rolling total. 

B. Sonoco shall continuously use the cyclone to control particulate matter When 

operating Boiler #1. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 9 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Sonoco.shall be limited to operating only Boiler #1 or Boiler #2 at any given 

time except for periods of start-up and shut-down. 

D. Emissions shall not exceed the following: 

Equipment PM PM10 SO2 

lb/MMBtu 0.47 

lb/hr 12.69 12.69 0.54 

NOx CO VOC 

4.59 0.54 

Eo Visible emissions from Boiler #1 shall not exceed 30% opacity on a 6 minute 

block average, except for no more than 2 six minute block averages in a 

continuous .3 hour period. 

(17) Boiler #2 

A. Fuel use shall not exceed 50,000 gal]yr of#6 fuel oil (12 month rolling total) 

with a maximum sulfur content not to exceed 0.5% by weight. Fuel records, 

including gallons used and percent sulfur, shall be maintained on a monthly 

basis, in addition to the 12 month rolling total. 

B. Sonoco shall be limited to operating only Boiler #1 or Boiler #2 at any given 

time except for periods of start-up and shut-down. 

C. Emissions shall not exceed the following: 

Equipment 

Boiler #2 lb/MMBtu 

lb/hr 

PM PMlo SO2 NOx CO 

0.20 

4.00 4.00 10.00 10.00 0.67 

VOC 

0.04 

D. Visible emissions from Boiler #2 shall not exceed 30% opacity on a 6 minute 

block average, except for no more than 2 six minute block averages in a 

continuous 3 hour period. 

(18) Emergency Generator 

A. Capacity shall not exceed 125 kW for the Emergency Generator. 

B. Facility shall limit the Emergency Generator to 500 hr/yr of operation (based 

on a 12 month rolling total). 

C. A log documenting the dates, times, and reason of operation for the 

Emergency Generator shall be kept. 

D. The Emergency Generator shall fire diesel with a sulfur limit not to exceed 

0.05% by weight. Fuel records, including percent sulfur, shall be maintained. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 10 

Departmental 

Findings of Fact and Order 

Air Emission License 

E. Emissions shall not exceed the following: 

Equipment 

Emergency 

Generator 

lb/MMBtu 

PM 

0.12 

PM•0 SO2 NOx 

lb/hr 0.15 0.15 0.06 5.38 

CO 

1.16 

VOC 

0.43 

Visible emissions from the Emergency Generator shall not exceed 20% 

opacity on a 6 minute block average, except for no more than 2 six minute 

block averages in a continuous 3 hour period. 

(19) Kilns 

A. Sonoco shall not exceed a yearly throughput in the kilns of 5 million board 

feet per year based on a 12 month rolling total. 

B. Sonoco shall keep monthly records of board feet processed. 

(20) Paint Booths 

A. Sonoco shall be limited to 3,500 gallons per year of paint, based on a 12 

month rolling total. 

B. Sonoco shall maintain monthly records indicating .the amount of paint 

received and the VOC content of the paint. 

C. Sonoco shall install and maintain particulate filters in the spray booths. 

D. Visible emissions from the paint booths shall not exceed 5% opacity on a 6 

minute block average basis. 

(21) Finger Joining Operation 

Sonoco shall not exceed a limit of 4.6 tons VOC per year from the finger joining 

operation, based on a 12 month rolling total. Compliance shall be demonstrated 

by monthly records indicating the amount of glue used and its VOC content. 

(22) Parts Washers 

Sonoco shall label the parts washer with operational standards, equip the washer 

with cover if the vapor pressure is >15 mmHG at 100°F, close cover when not in 

use, drain parts for 15 seconds or longer, keep drafts < 40 m/minute, repair leaks, 

and keep records of solvent added and removed. Sonoco shall not degrease 

porous material. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 11 

Departmental 

Findings of Fact and Order 

Air Emission License 

(23) 

(24) 

(25) 

Stockpiles and Roadways 

Potential sources of fugitive PM emissions including material stockpiles and 

roadways shall be controlled by wetting with water, with calcium chloride, or 

other methods as approved by the Bureau of Air Quality to prevent visible 

emissions in excess of 10% opacity, on a 3 minute block average basis. 

Sonoco shall notify the Department within 48 hours and submit a report to the 

Department on a quarterly basis if a malfunction or breakdown in any component 

causes a violation of any emission standard (Title 38 MRSA §605-C). 

Annual Emission Statement 

In accordance with MEDEP Chapter 137, the licensee shall annually report to 

the Department the information necessary to accurately update the State's 

emission inventory by means of: 

1) A computer program and accompanying instructions supplied by the 

Department; 

or 

2) A written emission statement containing the information required in 

MEDEP Chapter 137. 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 

The emission statement must be submitted by September 1. 
Sonoco Products Co. 

Somerset County 

North Anson, Maine 

A-103-71-I-R 12 

Departmental 

Findings of Fact and Order 

Air Emission License 

(26) The term of this Order shall be for five (5) years from the signature below. 

DONE AND DATED IN AUGUSTA, MAINE THIS 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

DAY OF 2001, 

BY: 

MARTHA G. KIRKPATRICK, COMMISSIONER 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date. of initial receipt of application: 

Date of application acceptance: 

3/14/01 

3/19/01 

Date filed with the Board of Environmental Protection: 

This Order prepared by Lynn Ross, Bureau of Air Quality. 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license application, .staff investigation reports and other 

documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 M.R.S.A., 

§344 and §590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Geneva Energy Maine LLC (Geneva Energy) has submitted an application to 

operate an existing wood fired boiler and a new wood chip dryer for the 

processing of wood pellets. The previous license under J & L Electric, formerly 

Forster manufacturing, for the boiler at the Strong facility expired, therefore this 

is considered a new license. Geneva Energy Maine LLC is the owner of the 

facility and Strong Green Energy LLC will be theon-site entity, responsible for 

managing the operations. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Fuel Burning Equipment 

Maximum Maximum Pollution 

Capacity Firing Rate Fuel Control 

Equipment •MMBtu/hr} (lb/hr}* Type Equipment Stack # 

Boiler 1 33.7 9361 wood multiclone 1 

* Based on 3600 Btu/lb wet wood/bark 

Process Equipment 

Equipment 

Dryer 1 

Max. Raw Material 

Process Rate 

19.8 tons/hr 

Max. Finished 

Material Process Rate 

12 tons/hr 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Application Classification 

A new source is considered a major source based on whether or not expected 

emissions exceed the "Significant Emission Levels" as defined in the 

Department's regulations. Emissions for the new source are determined by the 

maximum future license allowed emissions, as follows: 

Pollutant 

PM 

PM10 

SO2 

Max. Future 

License 

24.4 

24.4 

3.1 

Sia. Level 

100 

100 

100 

NOx 22.95 100 

CO 

VOC 

76.5 

49.9 

100 

50 

The Department has determined the facility is a minor source and the application 

has been processed through Major and Minor Source Air Emission License 

Regulations, 06-096 CMR ! 15 (last amended December 24, 2005). With the fuel 

limit on the boiler and the total VOC limit on the dryer, the facility is licensed 

below the major source thresholds and is considered a synthetic minor. 

II. BEST PRACTICAL TREATMENT (BPT) 

A. Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Definitions Regulation, 06-096 CMR 100 (last amended 

December 24, 2005). Separate control requirement categories exist for new and 

existing equipment as well as for those sources located in designated nonattainment areas: 

BPT for new sources and modifications requires a demonstration that emissions 

are receiving Best Available Control Technology (BACT)• as defined in 06-096 

CMR 100. BACT is a top-down approach to selecting air emission controls 

considering economic, environmental and energy impacts: 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-J42-71-M-N (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

Process Description 

]?he Geneva Energy facility will receive wood at the storage area. The wood will 

then be debarked, chipped, and conveyed to a screen. Bark from the debarker and 

any fines from the screens will be conveyed to the boiler silo. The silo fuel may 

be supplemented by purchased chips. 

The wood chips continue from the screens to a 'wet' surge bin and are metered 

into the dryer. The wood chips go through the dryer and then are transferred 

directly to. either a grinder or a 'dry' surge bin. 

The dry wood chips are ground to sawdust and go directly to the pelletizer. The 

pellets are vacuumed from the pelletizer and go through a tumbler to remove 

fines. These fines are returned to the pelletizer infeed. The finished pellets are 

conveyed to two 120 ton silos. 

The pellets are conveyed to the 'form, fill, and seal' automatic bagging system. 

The automatic bagging system unitizes the 40 pound bags and wraps them in one 

ton units on pallets. The pallets are readied for truck loading by forklift at the 

loading dock. 

Boiler #1 

Boiler #1 was manufactured in 1980.and has a maximum capacity of 33.7 

MMBtu/hr burning wood waste. It will be operated for heating, hot water, steam 

for the dryer, and steam for the turbine. The turbine turns a 1.25 megawatt 

generator. The flyash from the boiler is controlled by a rnulticyclone. 

The boiler's main fuel will include bark and screen fines, with supplemental 

purchased wood chips if necessary. The wood waste and chips are automatically fed to the boiler through a conveyer. The feed rate is governed by steam demand 

and excess oxygen requirements. The boiler may also fire specification waste oil 

generated on-site, not to exceed 60 gallons per month. The specification waste oil 

shall meet the definition in Waste Oil Management Rules, 06-096 CMR 860. 

The boiler was manufactured and installed in 1980, and is therefore not subject to 

the New Source Performance Standards (NSPS) 40 Code of Federal Regulations 

(CFR) Part 60, Subpart Dc for steam generating units greater than 10 MMBtu/hr 

manufactured after June 9, 1989. 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 4 

Departmental 

Findings of Fact and Order 

Air Emission License 

BA CT Findings 

Geneva Energy submitted a BACT analysis for controlling boiler operations 

which includes the use of an Alan Bradley programmable logic controller PLC to 

control the automatic boiler fuel feed, an oxygen monitor on stack to monitor 

boiler combustion efficiency, a smoke meter in stack to monitor opacity, and an 

induced draft fan on the boiler exhaust. Manual controls include a multicyclone 

collector for flyash, propane pre-fire for cold start-up to reduce emissions, and a 

stack economizer to increase efficiency of boiler. 

Geneva Energy shall meet the following BACT emission limits, based on a fuel 

heat •ontent of 3600 Btu/lb wood (55% moisture): 

PM/PM10 0.3 lb/MMBtu, per Fuel Burning Equipment Particulate Emission 

Standard, 06-096 CMR 103 (last amended Januar•¢ 24, 1983), and 10.1 

lb/hr. 

SO2 combustion of wood, 0.04 lb/MMBtu and 1.4 lb/hr 

NOx good combustion and previous license limit, 0.3 lb/MMBtu and 10.1 lb/hr 

CO good combustion and previous license limit, 1.0 lb/MMBtu and 33.7 lb/hr 

VOC good combustion and previous license limit, 0.06 lb/MMBtu and 2.0 lb/hr 

Opacity not to exceed 30% opacity on a 6 minute block average basis, except 

for no more than two 6 minute block averages in a 3 hour period, per 

Visible Emissions Regulations, 06-096 CMR 101 (last amended May 18, 

2003). 

The boiler shall be limited to 21,000 tons wood/year based on 3600 Btu/lb (or 

equivalent), on a 12 month rolling total. 

Geneva Energy shall keep maintenance logs on the multiclone. The log entries 

shall include details on malfunctions and routine maintenance (i.e. time, date, any 

corrective actions taken). 

C. Dr•,er #1 

Dryer #1 is a Bruks Klockner bed dryer. It is a low t6mperature dryer with 

controlled air supplied during continuous feeding and continuous moisture 

monitoring. Chips between 3⁄4 inch to 1 inch are expected to be used to minimize 

the opportunity for fine wood particles to be carried away in the exhaust air. In 

addition, the dryer is designed for minimal particulate emissions. 

An infeed auger spreads the material evenly across the dryer's entire width. A hot 

air flow of 80°C 110°C (176°F 230°F) from a tube system below passes through 

the slowly moving bed of material. The moisture content of the bed increases 
Geneva Energy Maine, LLC 

Franklin County 

Str.ong, Maine 

A-342-71-M-N (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

from the bottom of the material bed to the top. The top layer of moist material 

over the dryer's whole length provides for control of particulate matter. The top 

layer, which is too wet to pelletize, is skimmed off at the end by a vertically 

adjustable auger and returned to the beginning of the dryer. The auger's vertical 

position is controlled by a hygrometer which continuously monitors the desired 

moisture of the end product. The wet top layer is expected to be about 3-4 inches 

deep. The overall depth of material in the bed is expected to be from 31-39 

inches. 

Geneva Energy submitted information on the dryer, including test results. Based 

on these test results, Geneva Energy shall meet the following emissions limits 

from the dryer (total for all roof ducts): 

PM 0.34 lb/hr 

VOC 13.7 lb/hr 

To remain a minor source, Geneva Energy shall limit VOC emissions from the 

dryer to 45.4 tons/year. 

For particulate control, Geneva Energy shall ensure that there is a continuous wet 

moisture layer across the entire dryer at the proper depth to minimize particulate 

emissions. 

Geneva Energy shall perform PM and VOC stack tests on the dryer within six 

months of start-up. Based on the test results, the dryer limits may be revised. 

D. Pelletizer 

The pelletizer consists of two rotating dies that interlock. The pellets are formed 

through extrusion which results in heat and evaporation of moisture, and the 

pellets reach a temperature of 120°F. Once the pellets are produced, they are 

picked up by the vacuum system and moved to the tumbler and screening process. 

The tumbling and screening process removes the fines and sharp edges from the 

pellets. The screened fines are put back into the pelletizing process for reuse. 

Process cyclones control particulate matter. 

E. Bagging and Shipping 

The form, fill, and seal bagger is a fully automatic system in which the pellets end 

up in bags made from rolls of polyethylene pre-printed center-folded film. The 

bags are then stacked on a pallet in one ton units and wrapped by an automated 

system. A forklift removes the unitized pallets to the shipping area. 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

F. General Process Emissions 

BACT for the wood handling and transfer systems shall be the use of cyclones to 

control particulate emissions. Visible emissions from these general process 

sources, including the cyclones, screening operation, pelletizer operation, 

fuel/wood material conveying systems, and the pellet bagging operations, shall 

not exceed an opacity of 20% on a six (6) minute block average basis, except for 

no more than one (1) six (6) minute block average in a 1-hour period, per 06-096 

CMR 101. 

Go Fugitive Emissions 

Visible emissions from a fugitive emission source (including fuel/feed stockpiles 

and roadways) shall not exceed an opacity of 20%, except for no more than five 

(5) minutes in any 1-hour period. Compliance shall be determined by an 

aggregate of the individual fifteen (15)-second opacity observations which exceed 

20% in any one (1) hour, per 06-096 CMR 101 

H. Annual Emissions 

Geneva Energy shall be limited to the following annual emissions, based on a 12 

month rolling total, and calculated from an annual fuel limit of 21,000 tons/year 

wood waste (55% moisture) and dryer emissions: 

Total Licensed Annual Emissions for the Facility 

Tons/year 

(used to calculate the annual license-fee) 

PM 

Dryer 

PM•o SO2 

1.5 

NOx 

1.5 

CO 

Boiler 22.7 22.7 3.0 22.7 76.5 4.5 

Total TPY 24.2 24.2 

VOC 

45.4 

3.0 22.7 76.5 49.9 

Ill.AMBIENT AIR QUALITY ANALYSIS 

According to 06-096 CMR 115, the level of air quality analyses required" for a minor 

new source shall be determined on a case-by case basis. Modeling and monitoring 

are reqUired if the total emissions of any pollutant released meet or exceed the 

following: 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 7 

Departmental 

Findings of Fact and Order 

Air Emission License 

Pollutant 

PM 

PM•o 

'SO2 

NOx 

CO 

Tons/Year 

25 

50 

100 

250 

Based on the information available in the file, and the similarity to existing sources, 

and the license tons/year limits, Maine Ambient Air Quality Standards (MAAQS) 

will.not be violated by this source. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-342-71-M-N subject to the 

following conditions. 

Severability. The invalidity or unenforceability of any provision, or part thereof, of this 

License shall not affect the remainder of the provision or any other provisions. This 

License shall be construed and enforced in all respects as if such invalid or unenforceable 

provision or part thereof had been omitted. 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, conductfilg inspections, or examining and copying records relating to emissions 

(38 M.R.S.A. §347-C). 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

(2) The license• shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [06-096 CMR 115] 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [06-096 CMR 115] 

(4) 

(5) 

The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. [06-096 CMR 115] 

The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. [06-096 CMR 115] 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. [06-096 CMR 115] 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a maimer consistent with good air 

pollution control practice for minimizing emissions. [06-096 CMR 115] 

(8) The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [06-096 CMR 115] 

(9) The licensee shall comply with all terms and condition• of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [06-096 CMR 115] 

(10) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [06-096 CMR 115] 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

(11) 

(12) 

(13) 

In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuant to any other requirement of this license to perform stack testing. 

B. install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test completion. 

[06-096 CMR 115] 

If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

A. within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 

B. the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

C. the licensee may, upon the approval of the Department t•ollowing the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

[06-096 CMR 115] 

Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-7I-M-N (SM) 10 

Departmental 

Findings of Fact and Order 

Air Emission License 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [06-096 CMR 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[06-096 CMR 115] 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. [06-096 CMR 115] 

SPECIFIC CONDITIONS 

(16) B •..•1 (33.7 MMBtu/hr wood fired) 

A. Emissions from Boiler #1 shall not exceed the following: 

Pollutant lb/MMBtu 

PM 0.3 

PM•o 0.3 

NOx 0.3 

Origin and Authority 

06-096 CMR 103(2)(B)(4)(a) 

06-096 CMR 103(2)(B)(4)(a) 

06-096 CMR 115, BACT 

B. Emissions from Boiler #1 shall not exceed the following [06-096 CMR 115, 

BACT]: 

PM PMlo SOz NOx CO 

Ob/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) 

1O.1 10.1 1.4 10.1 

VOC 

(lb/hr) 

2.0 

C. Visible emissions from Boiler #1 shall not exceed 30% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. [06-096 CMR 101] 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 11 

Departmental 

Findings of Fact and Order 

Air Emission License 

Do Fuel use shall not exceed 21,000 tons/yr wood waste (3600 Btu/lb, 55% 

moisture), or equivalent. Fuel use records shall be maintained on a monthly 

basis, in addition to the 12 month rolling total. A description of the method 

used to calculate fuel use shall be submitted to the Bureau of Air Quality 

within 30 days of the issuance of this license. [06-096 CMR 115, BACT] 

Eo Geneva Energy may mix specification waste oil with the wood waste residue 

fired in the wood fired boiler. The specification waste oil use shall not exceed 

60 gallons/month. Records shall be maintained documenting the gallons of 

specification waste oil fired each month. 

Geneva Energy may mix oily rags with the wood waste residue fired in the 

wood fired boiler. The oily rags must originate from the facility and the 

permeated oil must meet the requirements of specification waste oil. Geneva 

Energy shall maintain records of the amount of oily rags burned each month 

(ie a full 55 gallon drum full, 1⁄2 drum, etc). 

An analysis of a representative waste oil sample shall be kept on site. If there 

are changes in the process or if there are changes in the maintenance garage 

that may effect the composition of the waste oil collected, a new 

representative sample shall be tested. These test results shall be kept on-site 

and a copy shall be submitted to the Bureau of Air Quality. 

[06-096 CMR 115, BACT and 06-096 CMR 860] 

(17) Dryer #1 

A. Emissions from the Dryer's ducts shall not exceed the following totals [06- 

096 CMR 115, BACT]: 

PM 

0b/hr) 

0.34 

PM10 VOC 

0b/hr) (lb/hr) 

0.34 13.7 

Bo Visible emissions from the dryer exhaust points shall not exceed 20% opacity 

on a 6-minute block average basis, except for no more than one 6-minute 

block average in a 3-hour period. [06-096 CMR 101] 

Co Geneva Energy shall ensure that there is a continuous wet moisture layer 

across the dryer at the proper depth to minimize particulate emissions and that 

the dryer will be operated within the manufacturers recommended temperature 

range. A compliance monitoring plan shall be submitted to the Department 

within 60 days of the issuance of this license detailing how these requirements 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 12 

Departmental 

Findings of Fact and Order 

Air Emission License 

will be met, including a proposal of a minimum wet moisture layer depth. 

[06-096 CMR 115, BACT] 

Geneva Energy shall limit VOC emissions from the dryer to 45.4 tons/year. A 

description of the method used to calculate compliance with the VOC 

tons/year limit shall be submitted to the Bureau of Air Quality within 30 days 

of the issuance of this license [06-096 CMR 115, BACT] 

Eo Geneva Energy shall record each startup, shutdown, and malfunction event 

including start time, end time, duration, cause, and method utilized to 

minimize the duration of the event and/or to prevent a reoccurrence. [06-096 

CMR 115] 

(18) Stack Testing 

Within six months of start-up, Geneva Energy shall perform PM and VOC stack 

tests on Dryer #1 and a PM stack test on Boiler #1 in accordance with the 

appropriate EPA test method. [06-096 CMR 115, BACT] 

(19) General Process Sources 

Visible emissions from any general process source (including the fuel/wood 

material conveying systems, the screening operation, the pelletizer operation, and 

the pellet bagging operations) shall not exceed an opacity of 20% on a six (6) 

minute block average basis, except for no more than one (1) six (6) minute block 

average in a 1-hour period. [06-096 CMR 101] 

(20) Fugitive Emissions 

Visible emissions from fugitive emission sources located at the facility (including 

fuel/feed stock stockpiles and roadways) shall not exceed 20% opacity, except for 

no more than five (5) minutes in any 1-hour period. Compliance shall be 

determined by an aggregate of the individual fifteen (15)-second opacity 

observations which exceed 20% in any one (1) hour. [06-096 CMR 101] 

(21) Malfunction and Breakdown 

Geneva Energy shall notify the Department within 48 hours and submit a report to 

the Department on a quarterly basis if a malfunction or breakdown in any 

component causes a violation of any emission standard (38 MRSA {}605). 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 13 

Departmental 

Findings of Fact and Order 

Air Emission License 

(22) Annual Emission Statement 

In accordance with Emission Statements, 06-096 CMR 137 (last amended July 6, 

2004), the licensee shall annually report to the Department the information 

necessary to accurately update the State's emission inventory by means of: 

1) A computer program and accompanying instructions supplied by the 

Department; 

or 

2) A written emission statement containing the information required in 06-096 

CMR 137. 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 Phone: (207) 287-2437 

The emission statement must be submitted by the date specified in 06-096 

CMR 137. 

(23) Air Toxics Emission Statement 

If Geneva Energy exceeds the thresholds for HAPs listed in Appendix A of 06- 

096 CMR 137 in an inventory year, in accordance with 06-096 CMR 137 the 

licensee shall report, every three years (2005, 2008, 2011, etc.) or as otherwise 

stated in 06-096 CMR 137, the information necessary to accurately update the 

State's toxic air pollutants emission inventory in a format prescribed by the 

Department containing the information required in 06-096 CMR 137. 

NOTE: Based .on AP-42 emission factors for fuel burning equipment, Geneva 

Energy will most likely exceed the 06-096 CMR 137 thresholds of HAPs based 

on fuel burning alone should the facility exceed the firing of 250 tons of wood 

waste (50% moisture) in a calendar year. 
Geneva Energy Maine, LLC 

Franklin County 

Strong, Maine 

A-342-71-M-N (SM) 14 

Departmental 

Findings of Fact and Order 

Air Emission License 

Reports and questions should be directed to: 

Attn: HAP Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-001.7 

[06-096 CMR 137] 

Phone: (207) 287-2437 

DONE AND DATED 1N AUGUSTA, MAINE THIS 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

DAY OF 2007. 

BY: 

DAVID P. LITTELL, COMMISSIONER 

The term of this license shall be five (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: November 20, 2007 

Date of.application acceptance: November 26, 2007 

Date filed with the Board of Environmental Protection: 

This Order prepared by Kathleen E. Tarbuck, Bureau of Air Quality. 
Hancock Lumber / Ryefield 

Cumberland County 

Casco, Maine 

A-629-71-G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

After review of the air emissions license renewal application, staff investigation reports 

and other documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 

M.R.S.A., Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Hancock Lumber / Ryefield (Hancock) of Casco, Maine has applied to renew 

their Air Emission License permitting the operation of emission sources 

associated with their lumber manufacturing facility. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Fuel Burning Equipment 

Maximum Maximum 

Equipment Capacity Firing Rate 

(MMBtu/hr) (•al/hr) 

Boiler #2 13.6 97 gal/hr 

Boiler #3 10.8 1.2 ton/hr 

Fuel Type, 

% sulfur 

#2 fuel oil, 0.35% 

.•.9od waste, negligible 

St•ack # 

2 

3 

Process Equipment 

Equipment 

Kilns (5) 

Production Rate Pollution Control Stack # 

Equipment 

20 MMBFT/yr None N/A 

Co Application Classification 

The application for Hancock does not include the licensing Of increased emissions 

or the installation of new or modified equipment. Therefore, the license is 

considered to be a renewal of current licensed emission units only and has been 

processed through Chapter 115 of the Department's regulations. 
Hancock Lumber / Ryefie.ld 

Cumberland County 

Casco, .Maine 

A-629-71-G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

II. BEST PRACTICAL TREATMENT (BPT) 

Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for existing emissions equipment means that method which controls or 

reduces emissions to the lowest possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emissions 

from the source being considered; and 

the economic feasibility for the type of establishment involved. 

Bo Boiler #2 

Boiler #2 is Cleaver Brooks oil fired boiler. This boiler is rated at 97 gallons of 

fuel per hour which corresponds to a heat input of 13.6 MMBtu/hr. Boiler #2 was 

previously licensed at a heat input of 14.6 MMBtu/hr. Thi• heat input is stamped 

on the unit's boiler plate however it is based on the firing of#6 fuel oil instead of 

#2 oil. Boiler #2 is used in the winter for additional heat to the kilns. 

NSPS requirements 

Boiler #2 was manufactured in 1982, and is therefore not subject to the New 

Source Performance Standards (NSPS) Subpart Dc for steam generating units 

greater than 10 MMBtu/hr manufactured after June 9, 1989. 

A summary of the BPT analysis for Boiler #2 (13.6 MMBtu/hr) is the following: 

1. The total fuel use for Boiler #2 shall not exceed 200,000 gal/year of #2 fuel 

oil, based on a 12 month rolling total, with a maximum sulfur content not to 

exceed 0.35%, by weight. 

2. Chapter 106 regulates fuel sulfur content, however in this case a BPT analysis 

for SO2 determined a more stringent limit of 0.35% was appropriate and shall 

be used. 

3. Chapter 103 regulates PM emission limits. The PM10 limits are derived from 

the PM limits. 

4, NOx emission limits are based on data from similar #2 fired boilers of this size 

and age. 

5. CO.and VOC emission limits are based upon AP-42 data dated 9/98. 

6. Visible emissions from Boiler #2 shall not exceed 20% opacity on a six (6) 

minute block average, except for no more than one (1) six (6) minute block 

averages in a continuous 3-hour period. 
Hancock Lumber / Ryefield 

Cumberland County 

Casco, Maine 

A-629-71-G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

Co 

Do 

Boiler #3 

Boiler #3 is a wood fired boiler with a maximum heat input of 10.8 MMBtu/hr 

firing wood waste with an average moisture content of 50%, by weight. Wood 

waste includes sawdust, shavings, trim pieces, and bark. This boiler was licensed 

after-the-fact and installed earlier this year to replace Boiler # 1. 

NSPS requirements 

Boiler #3 was manufactured in 1986 and is therefore not subject to the New 

Source Performance Standards (NSPS) Subpart Dc for steam, generating units 

greater than 10 MMBtu/hr manufactured after June 9, 1989. 

A summary of the BPT analysis for Boiler #3 (10.8 MMBtu/hr) is the following: 

1. The total fuel use for Boiler #3 shall not exceed 10,500 ton/year (12-month 

rolling total) of wood based on a moisture content of 50%. 

2. Hancock shall use the following formula, when necessary, to convert fuel use 

records .to 50% moisture: 

Tons Wood at 50% (Tons Wood at M%) x [(100-M)/50] 

where M the moisture content of the actual wood fired 

3. Hancock shall continuously operate the fly ash re-injection on Boiler #3 when 

Boiler #3 is in operation. 

4. Chapter 103 regulates PM emission limits. However, a recent BACT analysis 

determined a PM limit of 0.30 lb/MMBtu was more appropriate and shall be 

used. The PM 10 limits are derived from the PM limits. 

5. SO2, NOx, CO, and VOC emission limits are based upon AP-42 data dated 

9/03. 

6. Visible emissions from Boiler #3 shall not exceed 30% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. 

Kilns 

Hancock operates five kilns for drying lumber. Heat for the kilns is provided by 

Boilers #2 and/or #3. Yearly throughput is limited to 20.0 million board feet per 

year based on a 12 month rolling total. 

Visible emissions from any general process source shall not exceed an opacity of 

20% on a six (6) minute block average basis, except for no more than one (1) six 

(6) minute block average in a 1-hour period. 
Hancock Lumber / Ryefield 

Cumberland County 

Casco, Maine 

A-629-71-G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

Annual Emissions 

Hancock shall be restricted to the following annual emissions, based on a 12 

month rolling total: 

Total Licensed Annual Emission for the Facility 

Tons/year 

(used to calculate the annual license fee) 

Boiler #2 

Boiler #3 

Kilns 

Total TPY 

PM 

1.7 

14.2 

15.9 

PM•0 

1.7 

14.2 

15;9 

SO2 

4.9 

1.2 

6.1 

NOx 

4.9 

10.4 

15.3 

CO 

0.5 

28.4 

28.,9 

VOC 

0.1 

0.8 

22.6 

23.5 

III.AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a renewal source shall be determined on a case-by case basis. Modeling and 

monitoring are not required for a renewal if the total emissions of any pollutant released 

do notexceed the following: 

Pollutant 

PM 

PM10 

Tons/Year 

25 

25 

SO2 50 

NOx 

CO 

100 

250 

Based on the above total facility emissions, Hancock is below the emissions level 

required for modeling and monitoring. 
Hancock Lumber / Ryefield 

Cumberland County 

Casco, Maine 

A-629-71-G-R 5 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-629-71-G-R subject to the 

following conditions. 

Severability. The invalidity or unenforceability of any provision, or part thereof, of this 

License shall not affect the remainder of the provision or any other provisions. This 

License shall be construed and enforced in all respects as if such invalid or unenforceable 

provision or part thereof had been omitted. 

STANDARD CONDITIONS 

(1) 

(2) 

(3) 

(4) 

Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(38 MRSA §347-C). 

The licensee Shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [MEDEP Chapter 115] 

Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [MEDEP Chapter 115] 

The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request.[MEDEP Chapter 115] 
Hancock Lumber / Ryefield 

Cumberland County 

Casco, Maine 

A-629-71-G-R 6 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. [MEDEP Chapter 115] 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. [MEDEP Chapter 115] 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. [MEDEP Chapter 115] 

(8) The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [MEDEP Chapter 115] 

(9) The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [MEDEP Chapter 115] 

(10) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuant to any other requirement of this license to perform stack testing. 

B. install or make provisions to install test ports that meetthe criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test completion. 

[MEDEP Chapter 115] 
Hancock Lumber / Ryefield 

Cumberland CountyCasco, Maine 

A-629-71-G-R 7 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

(12) 

(13) 

(14) 

(15) 

If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable Standards, then: 

A. within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 

B. the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

C. the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

[MEDEP Chapter 115] 

Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [MEDEP Chapter 115] 

The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 115] 

Upon written .request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. [MEDEP Chapter 115] 
Hancock Lumber / Ryefield 

Cumberland County 

Casco, Maine 

A-629-71-G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

SPECIFIC CONDITIONS 

(16) Boiler #2 

Ao Total fuel use for Boiler #2 shall not exceed 200,000 gal/yr of#2 fuel oil with 

a maximum sulfur content not to exceed 0.35%, by weight. Compliance shall 

be demonstrated by fuel records from the supplier showing the quantity of fuel 

delivered and the percent sulfur of the fuel. Fuel use records shall be kept on 

a 12-month rolling total basis. [MEDEP Chapter 115, BPT] 

B. Hancock shall not fire Boiler #2 with any type of rain cap obstructing the 

stack exit. [MEDEP Chapter 115, BPT] 

C. Emissions shall.not exceed the following: 

Emission Unit 

Boiler #2 

Pollutant 

PM 

Ib/MMBtu Origin and Authority 

0.12 MEDEP, Chapter 103, 

Section 2(B)(1)(a) 

D. Emissions shall not exceed the following [MEDEP Chapter 115, BPT]: 

(17) 

Emission 

Unit 

Boiler #2 

PM 

(lb/hr) 

1.64 

PMlo SOz NOx 

(lb/hr) (lb/hr) Ob/hr) 

1.64 4.80 4.76. 

CO 

(lb/hr) 

0.49 

VOC 

(lb/hr) 

0.02 

Eo Visible emissions from Boiler #2 shall not exceed 20% opacity on a six (6) 

minute block average, except for no more than one (1) six (6) minute block 

averages in a continuous 3-hour period. [MEDEP Chapter ! 01 

Boiler #3 

mo Total fuel use for Boiler #3 shall not exceed 10,500 ton/yr at 50% moisture, 

by weight (or equivalent) of wood waste. Fuel use records shall be kept on a 

12-month rolling total basis. [MEDEP Chapter 115, BPT] 
Hancock Lumber / Ryefield 

Cumberland County 

Casco, Maine 

A-629-71-G-R 

B. Emissions Shall not exceed the following: 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

Emission Unit Pollutant 

Boiler #3 PM 

lb/MMBtu Origin and Authority 

0.30 MEDEP Chapter 115, BACT 

C. Emissions shall not exceed the following [MEDEP Chapter 115, BPT]: 

(18) 

(19) 

(20) 

Emission PM PM•0 

Unit (lb/hr) (lb/hr) 

Boiler #3 3.24 3.24 

SO2 NOx 

(lb/hr) (lb/hr) 

0.27 2.38 

CO VOC 

(lb/hr) (lb/hr) 

6.48 0.18 

Hancock shall continuously operate fly ash re-injection on Boiler #3 

whenever Boiler #3 is in operation. Hancock shall keep a log of maintenance 

performed on the fly ash re-injection system. [MEDEP Chapter 115, BPT] 

Eo Visible emissions from Boiler #3 shall not exceed 30% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. [MEDEP Chapter 101] 

Kilns 

A. Hancock's kilns shall not exceed a yearly throughput of 20.0 million board 

feet per year, based on a 12 month rolling total. 

Hancock shall keep monthly records of board feet processing in the kiln. 

Visible emissions from any general process source shall not exceed an opacity 

of 20% on a six (6) minute block average basis, except for no more than one 

(1) six (6) minute block average in a 1-hour period. [MEDEP Chapter 101] 

Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles, 

roadways, and sawdust handling activities) shall not exceed an opacity of 20%, 

except for no more than five (5) minutes in any 1-hour period. Compliance shall 

be determined by an aggregate of the individual fifteen (15)-second opacity 

observations which exceed 20% in any one (1) hour. [MEDEP Chapter 101] 

Hancock shall notify the Department within 48 hours and submit a report to the 

Department on.a quarterly basis if a malfunction or breakdown in any component 

causes a violation of any emission standard (Title 38 MRSA §605). 
Hancock Lumber / Ryefield 

Cumberland County 

Casco, Maine 

A-629-71-G-R 10 

Departmental 

Findings of Fact and Order 

Air Emission License 

Renewal 

(21) Annual Emission Statement 

In accordance with MEDEP Chapter 137• the licensee shall annually report to the 

Department the information necessary to accurately update the State's emission 

inventory by means of: 

1) A computer program and accompanying instructions supplied by the 

Department; 

or 

2) A written emission statement containing the information required in 

MEDEP Chapter 137. 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 

The emission statement must be submitted by July or as otherwise 

specified in Chapter 137. 

(22) Air Toxics Emission Statement 

If Hancock exceeds the thresholds for HAPs listed in Appendix A of MEDEP 

Chapter 137 in an inventory year, in accordance with MEDEP Chapter 137 the 

licensee shall report, no later than July every three years (2005, 2008, 2011, 

etc.) or as otherwise stated in Chapter 137, the information necessary to 

accurately update the State's toxic air pollutants emission inventory by means of a 

computer program supplied by the Department or a written emission statement 

containing the information required in MEDEP Chapter 137. 

NOTE: Based on AP-42 emission factors for fuel burning equipment, Hancock 

will most likely exceed the Chapter 137 thresholds of HAPs based on fuel burning 

alone should the facility exceed the firing of 250 tons of wood waste (50% 

moisture) in a calendar year. 
Hancock Lumber / Ryefield 

Cumberland County 

Casco, Maine 

A-629-71-G-R 11 

Departmental 

Findings of Fact and Order 

Air Emission License 

Ren ewal 

Reports and questions should be directed to: 

HAP Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 [MEDEP Chapter 137] 

(23) Payment of Annual License Fee 

Hancock shall pay the annual air emission license fee within 30 days of April 30th 

of each year. Pursuant to 38 MRSA §353-A, failure to pay this annual fee in the 

stated timeframe is sufficient grounds for revocation of the license under 38 

MRSA §341-D, subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

DAY OF 2006. 

BY: 

DAVID P. LITTELL, COMMISSIONER 

The term of this license shall be five (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: 4/25/06 

Date of application acceptance: 5/12/06 

Date filed with the Board of Environmental Protection: 

This Order prepared by Eric Kennedy, Bureau of Air Quality. 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

Departmental 

Findings .of Fact and Order 

Air Emission License 

After review of the air emissions license renewal application, staff investigation reports 

and other documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 

M.R.S.A., Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Andover Wood Products, Inc. (Andover Wood), a division of Ethan Allen has 

submitted an air emission license renewal application for the operation of 

emission sources associated with the lumber and furniture panel manufacturing 

facility located in Andover, Maine. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Boilers 

Maximum 

Capacity Fuel Type, 

Equipment (MMBtu/hr) %Sulfur 

Boiler 2 14.6 #2 oil, 0.3% S 

_Boiler 3 12.0 

Post 

Max. Firing Combustion Stack 

Rate °Control _# 

97 gal/hr None 2 

0.65 tons/hr Separator 1 

Note: There is no Boiler 1 on site it was previously removed. 

Diesel Generator 

Power .Output Firing Rate 

170 kW 10 gal/hr 

Fuel Type, 

% sulfur 

Diesel, 0.05% S 

Max. Input 

Capacity 

1.4 MMBtu/hr 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Application Classification 

The application for Andover Wood does not include the licensing of additional 

increased emissions or the installation of new or modified equipment. Therefore, 

the license is considered to be a renewal of current licensed emission units only 

and has been processed through Chapter 115 of the Department's regulations. 

With the fuel limit on boiler 2 and the operating hours restriction on the 

emergency generator, the facility is licensed below the major source thresholds 

and is considered a synthetic minor. 

The license does include various emission clarifications based on updated AP-42 

emission values. The facility emissions using the new emission factors for SO2 

CO, and VOC have decreased and NOx has increased as compared to the previous 

license. 

II. BEST PRACTICAL TREATMENT (BPT) 

A. Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Department's regulations. Separate 

control requirement categories exist for new and existing equipment as well as for 

those sources located in designated non-attainment areas. 

BPT for existing emissions equipment means that method .which controls or 

reduces emissions to the lowest possible level c, onsidering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emissions 

from the source being considered; and 

the economic feasibility for the type of establishment involved. 

Process Description 

Andover Wood manufactures lumber and furniture panels. The facility includes 

the sawmills, dry kilns, process area, fuel storage, and two boilers. Bark, grit, and 

high moisture material from the sawmill operations is sold rather than burned in 

the boilers. Boiler fuel consists of oil for one boiler and dxied wood waste from 

the sawing and planing operations for the main boiler. Boiler 2 (oil) and 3 (wood) 

exhaust through separate Stacks. 

The logs, mostly maple, enter the sawmill and are rough cut into boards. 

Following the sawmill, the boards are brought to one of the 8 kilns where drying 

occurs. From the kilns, the boards go to the process area. The boards are cut to 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

size, planed, and glued together per specific order requirements and are shipped to 

another facility for assembly. 

The majority of wood waste from the sawmill (high moisture) is hogged and piled for sale. 

The wood rejects from the process area are hogged and used as boiler fuel. 

The fines from a large portion of the process area are collected, sent through a 

baghouse, and sold. This collection system consists of pulling the fine-laden air 

from the individual pieces of equipment, piping it to the baghouse unit located 

outside of the process building, exhausting the clean air, and then piping the fines 

to a storage building where the fines are then sold. 

The wood waste for the boiler comes from a number of different areas. On the 

boiler house, there are 5 cyclones that are part of the fuel transport system. One 

cyclone is for the dried hogged wood waste coming from the process area. Two 

cyclones are for the wood waste from those saws in the process area that aren't 

collected by the baghouse system. One cyclone is for wood from the sawmill that 

is occasionally mixed in with the dry wood. The fifth cyclone is for feeding the 

boiler. 

B. Boiler 2 

Boiler 2 is a Cleaver Brooks fire tube package boiler rated at 14.6 MMBtu/hr. 

The boiler fh'es #2 fuel oil and exhausts through it's own stack. Boiler 2 shall be 

limited to 300,000 gallons/year of fuel oil, based on a 12 month rolling total. 

Monthly fuel use and the 12 month rolling total fuel use records shall be 

maintained. 

Andover Wood shall meet the following BPT emission limits for Boiler 2: 

PM/PM10 0.2 lb/MMBtu- based on Chapter 103 

SO 2 Use of#2 fuel with 0.3% •ulfur 

NO x 0.5 lb/MMBtu based on previous license 

CO good combustion, 0.5 lb/hr based on the newest AP-42 factor dated 

9/98 (5 lb/1000 gal) 

VOC good combustion, 0.02 lb/hr based on the newest AP-42 factor dated 

9/98 (0.2 lb/1000 gal) 

Opacity Visible emissions from Boiler 2 shall not exceed 20% opacity on a 

six (6) minute block average, except for no more than one (1) six (6) 

minute block averages in a 3-hour period, based on Chapter 101 of the 

Department's regulations. 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Boiler 3 

Boiler 3 is a 1924 Dillon boiler rated at 125 psig and 12 MMBtu/hr. In 1992 

when the boiler was installed at Andover Wood, a new Dutch oven, underfire air, 

overfire air and fuel feed system were installed on.the boiler. The majority of 

wood burned in the boiler is kiln dried sawdust and shavings with a mixture of 

green sawdust for a moisture content of approximately 10% (8100 Btu/lb). 

Boiler 3 shall meet the following BPT emission limits: 

PM/PM10 -0.3 lb/MMBtu- based on Chapter 103 

SO2 use of wood, 0.3 lb/hr based on the newest AP-42 emission factor 

dated 9/03 (0.025 lb/MMBtu) 

NO x 0.49 lb/MMBtu based on the newest AP-42 emission factor for dry 

wood dated 9/03 (0.49 lb/MMBtu, less than 20% moisture ) 

CO good combustion, 7.2 lb/hr based on the newest AP-42 emission factor 

dated 9/03 (0.6 lb/MMBtu) 

VOC good combustion, 0.2 lb/hr based on the newest AP-42 emission 

factor dated 9/03 (0.017 lb/MMBtu) 

Opacity Visible emissions from Boiler 3 shall not exceed 30% opacity on a 

six (6) minute block average, except for no more than two (2) six (6) 

minute block averages in a 3-hour period, based on Chapter 101 of the 

Department's regulations. 

Boiler 3 exhausts through a Breslove Separator and then up the 48 foot stack (the 

stack height is measured from the top of the separator, which is elevated). The 

separator is a regenerative fly ash separator that works on the principle of 

cyclonic separation. 

D. Emergency Generator 

The emergency diesel generator is rated at 170 KW (approximately 1.4 

MMBtu/hr), bums diesel fuel, and is used for emergency back-up generation. 

The generator fires 0.05% sulfur oil and is limited to 500 hours/year based on a 12 

month rolling total. 

"Emergency" is defined in Chapter 100 of the Department.'s regulations and 

throughout this document as: "... any situation arising from sudden and 

reasonably unforeseeable events beyond the control of the source, including acts 

of God, which situation requires immediate corrective action to restore normal 

operation, and that causes the source to exceed a technology based emission 

limitation under the license, due to unavoidable increases in emissions attributable 

to the emergency. An emergency shall not include noncompliance to the extent 

caused by improperly designed equipment, lack of preventative maintenance, 

careless or improper operation, or operator error." 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

The emergency generator shall meet the following BPT emission limits: 

PM/PM•0 0.43 lb/hr based on the AP-42 emission factor dated 10/96 (0.31 

lb/MMBtu) 

SO2 use of 0.05% sulfur fuel 

NO x 6.2 lb/hr based on the AP-42 emission factor dated 10/96 (4.41 

lb/MMBtu) 

CO good combustion, 1.3 lb/hr based on the AP-42 emission factor dated 

10/96 (0.95 lb/MMBtu) 

VOC good combustion, 0.5 lb/hr based on the AP-42 emission factor dated 

10/96 (0.36 lb/MMBtu) 

Opacity Visible emissions from the emergency generator shall not exceed 

30% opacity on a 6 minute block average basis, except for no more than 

2 six minute block averages in a 3-hour period, based on Chapter 101 of 

the Department's regulations. 

E. Material Handling and Storage 

The material transport system for dried sawdust and shavings consists of enclosed 

conveyor systems, cyclones, and a baghouse system. Routine maintenance at the 

facility includes inspections so that any leakage is quickly repaired and spilled 

sawdust is collected to prevent wind entrainment. 

Andover Wood has a few different stockpiles of wood wasteat the facility. Steps 

should be taken to minimize fugitive air emissions from these piles; including 

placing the piles in sheltered areas, cleaning up wind blown or spilled particulate 

matter, or using another minimization method(s). 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed an opacity of 20%, except for no more than five (5) 

minutes in any 1-hour period, based on Chapter 101 of the Department's 

regulations. Compliance shall be determined by an aggregate of the individual 

fifteen (15)-second opacity observations which exceed 20 percent in any one (1) 

hour. 

F. Gluing Operations 

The manufacturing of seats and other furniture products requires the gluing of 

dimension stock. The adhesive used by Andover Wood is a water borne product 

with a VOC content less than 5 g/1. The product is considered non-hazardous, has 

no known chronic effects, and contains no substance at or above the SARA 

Section 313 reportable thresholds. Use of a water borne adhesive represents BPT 

for the gluing operations. Andover Wood shall not exceed 5 tons/year VOC from 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

gluing operations, based on a 12 month rolling total and shall keep records 

documenting compliance with the VOC limit. 

G. Annual Emissions 

Andover Wood shall be restricted to the following annual emissions, based on a 

12 month rolling total: 

Total Licensed Annual Emission for the Facility 

Tons/year 

(used to calculate the annual license fee) 

PM PM10 SO2 NOx CO VOC 

Boiler 2 4.5 4.5 6.8 10.8 0.8 0.03 

Boiler 3 

Emergency 

Generator 

15.8 

0.1 

15.8 

0.1 

1.3 

0.02 

25,8 

1.5 

31.5 

0.3 

0.9 

0.1 

Gluing Operations 5 

Total TPY 120.4 20.4 8.1 138.1132.6 6.0 

III.AMBIENT AIR QUALITY ANALYSIS 

According to Chapter 115 of the Department's regulations, the level of air quality 

analyses required for a renewal source shall be determined on a case-by case basis. 

Modeling and monitoring are not required for a renewal if the total emissions of any 

pollutant released do not exceed the following: 

Pollutant Tons/Year 

PM 25 

PM•0 25 

SOz 50 

NOx 100 

CO 250 

Based on the above total facility emissions, Andover Wood is below the emissions level 

required for modeling and monitoring. 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-317-71-I-R (SM) subject to the 

following conditions: 

STANDARD CONDITIONS 

(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(38 MRSA §347-C). 

The licensee Shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [MEDEP Chapter 115] 

Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Departmen• may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [MEDEPChapter 115] 

The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which .may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. [MEDEP Chapter 115] 

The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to 38 M.R.S.A: §353. [MEDEP Chapter 115] 

The license does not convey any property rights of any sort, or any exclusive 

privilege. [MEDEP Chapter 115] 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

(7) 

(8) 

(9) 

(I0) 

(11) 

(12) 

The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. [MEDEP Chapter 115] 

The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [MEDEP Chapter 115] 

The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [MEDEP Chapter 115] 

The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 

In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuant to any other requirement of this license to perform stack testing. 

B. install or make provisions to install test ports that meet'the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test completion. 

[MEDEP Chapter 115] 

If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

A. within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 

B. the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

C. the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

[MEDEP Chapter 115] 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [MEDEP Chapter 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 115] 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. [MEDEP Chapter 115] 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

) 

) 

) 

10 

Departmental 

Findings of Fact and Order 

Air Emission License 

SPECIFIC CONDITIONS 

(16) Boiler 2 

Boiler 2 (14.6 MMBtu/hr) shall not exceed 300,000 gal/yr of #2 fuel oil, on a 

12 month rolling total. The maximum sulfur content of the #2 fuel shall not 

exceed 0.3% by weight. Compliance shall be demonstrated by fuel receipts 

from the supplier showing the quantity of fuel delivered and the percent sulfur 

of the fuel. Records of fuel use shall be kept on a monthly and 12-month 

rolling total basis. [MEDEP Chapter 115, BPT] 

B. Emissions from boiler 2 shall not exceed the following [MEDEP Chapters 103 

and 115, BPT]: 

Pollutant 

PM 

lb/MMBtu 

0.2 

Ib/hr 

2.9 

Co Visible emissions from Boiler 2 shall not exceed 20% opacity on a six (6) 

minute block average, except for no more than one (1) six (6) minute block 

averages in a 3-hour period. [MEDEP Chapter 101 

(17) 

A. Boiler 3 (12 MMBtu/hr) shall fire wood waste. Fuel use records shall be kept 

on a monthly and 12-month rolling total basis. [MEDEP Chapter 115, BPT] 

B. Emissions from boiler 3 shall not exceed the following [MEDEP Chapters 103 

and 115, BPT]: 

Pollutant lb/MMBtu lb/hr 

PM 0.3 3.6 

PM•0 .3.6 

SO2 0.3 

NOx 5.9 

CO 7.• 

VOC 0.20 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

) 

) 

) 

11 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Visible emissions from Boiler 3 shall not exceed 30% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a 3-hour period. [MEDEP Chapter 101 

(18) Emergency Generator 

Andover Wood shall limit the emergency generator to 500 hr/yr of operation 

(based on a 12 month rolling total). An hour meter shall be maintained and 

operated on the emergency generator. [MEDEP Chapter 115, BPT] 

Bo The generator shall be utilized only in emergencies and for short periods of 

periodic test firing of the unit for maintenance purposes. A log documenting 

the dates, times, and reason of operation for the emergency generator shall be 

kept. [MEDEP Chapter 115, BPT] 

The emergency generator shall fire diesel fuel oil with a sulfur limit not to 

exceed 0.05% by weight. Compliance shall be based on fuel receipts from the 

supplier showing the quantity of fuel delivered and the percent sulfur of the 

fuel. [MEDEP Chapter. 115, BPT] 

D. Emissions from the emergency generator shall not exceed the following 

[MEDEP Chapter 115, BPT]: 

Pollutant lb/hr 

PM 

PM10 

0.4 

0.4 

SO2 0.07 

NOx 6.2 

CO 1.3 

VOC 0.5 

Eo Visible emissions from the emergency generator shall not exceed 30% opacity 

on a six (6) minute block average, except for no more than two (2) six (6) 

minute block averages in a 3-hour period. [MEDEP Chapter 101] 

(19) Gluing Operations 

Andover Wood shall be limited to 5 tons/year VOC from gluing operations, based 

on a 12 month rolling total. Records shall be maintained documenting the amount 

of adhesive used, the VOC content of the adhesive, the total .monthly VOC 

emissions, and the 12 month rolling total of VOC emissions. [MEDEP Chapter 

115, BPT] 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

) 

) 

) 

12 

Departmental 

Findings of Fact and Order 

Air Emission License 

(20) General Process Sources 

Visible emissions from any general process source shall not exceed an opacity of 

20% on a six (6) minute block average basis, except for no more than one (1) six 

(6) minute block average in a l-hour period. [MEDEP Chapter 101, BPT] 

(21) Fugitive Emissions 

Visible emissions from a fugitive emission source (inciuding stockpiles and 

roadways) shall not exceed an opacity of 20%, ex6ept for no more than five (5) 

minutes in any 1-hour period. Compliance shall be determined by an aggregate of 

the individual fifteen (15)-second opacity observations which exceed 20 percent 

in any one (1) hour. [MEDEP Chapter 101, BPT] 

(22) Malfunction/Breakdown 

Andover Wood shall notify the Department within 48 hours and submit a report to 

the Department on a quarterly basis if a malfunction or breakdown in any 

component causes a violation of any emission standard (38 MRSA §605). 

(23) Annual Emission Statement 

In accordance with MEDEP Chapter 137, the licensee shall annually report to the 

Department the information necessary to accurately update the State's emission 

inventory by means of: 

1) A computer program and accompanying instructions supplied by the 

Department; 

or 

2) A written emission statement containing the information required in 

MEDEP Chapter 137. 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 

The emission statement must be submitted by the date specified in Chapter 

137. 
Andover Wood Products, Inc. 

Oxford County 

Andover, Maine 

A-317-71-I-R (SM) 

) 

) 

) 

13 

Departmental 

Findings of Fact and Order 

Air Emission License 

(24) Payment of Annual License Fee 

Andover Wood shall pay the annual air emission license fee within 30 days of 

December 31 of each year. Pursuant to 38 MRSA §353-A, failure to pay this 

annual fee in the stated timeframe is sufficient grounds for revocation of the 

license under section 341-D, subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

2004. 

BY: 

DAWN R. GALLAGHER, COMMISSIONER 

The term of this license shall be five (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: January 29, 2004 

Date of application acceptance: Febcuary 17, 2004 

Date filed with the Board of Environmental Protection: 

This Order prepared by Kathleen E. Molokie, Bureau of Air Quality. 
Roy Continental Mill, LLC 

Androscoggin County 

Lewiston, Maine 

A-392-71=E-R 

) 

) 

) 

) 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license renewal application, staff investigation reports 

and other documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 

M.R.S.A., Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Roy Continental Mill, LLC of Lewiston, Maine has applied to renew their Air 

Emission License. permitting the operation of emission sources associated with 

their manufacturing and storage rental facility. 

B. Emission EquipmentRoy Continental Mill, LLC is authorized to operate the following equipment: 

Fuel Burning Equipment 

Equipment 

Boiler #1 

Boiler #2 

Maximum 

Capacity 

(MMBtu/hr) 

20.3 

16.5 

Maximum 

Firing Rate 

(•al/hr) 

135 

110 

Fuel Type, 

%Sulfur 

#6 fuel oil, 0.5%S 

#6 fuel oil, 0.5%S 

Stack # 

C. ApplicationClassification 

The application for Roy Continental Mill, LLC does not include the licensing of 

increased emissions or the installation of new or modified equipment. Therefore, 

the.license is considered to be a renewal of current licensed emission units only. 
Roy Continental Mill, LLC 

Androscoggin County 

Lewiston, Maine 

A-392-71-E-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

II. BEST .PRACTICAL TREATMENT (BPT) 

A. Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as dofined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for existing emissions equipment means that method which controls or 

reduces emissions to the lowest possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emission 

from the source being considered; and 

the economic feasibility for the type of establishment involved. 

B. Emissions Units 

Roy Continental Mill, LLC operates Boilers #1 and #2 primarily for facility 

heating needs. Boilers # 1 and #2 have a maximum design heat input capacity of 

20.3 MMBtu/hr and 16.5. MMBtu/hr, respectively; firing #6 fuel oil. Boilers #1 

and #2 were manufactured in 1971 and 19,65, respectively, and are therefore not 

subject to EPA New Source Performance Standards (NSPS) Subpart Dc, for 

boilers with a heat input of 10 MMBtu/hr or greater and manufactured after June 

9, 1989. 

Roy ContinentalMill, LLC was previously licensed to burn up to 150,000 gallons 

per year (gal/yr) of #6 fuel oil based on a twelve-month rolling total. Roy 

Continental Mill, LLC has not requested a change in this limit and shall continue 

to be subject to this limit. Also as previously licensed, Roy Continental Mill, 

LLC shall fire only #6 fuel oil with a sulfur content of no greater than 0.5% sulfur 

by weight. Compliance with •he above fuel restrictions shall be demonstrated 

through fuel receipts from the supplier showing the quantity of fuel delivered and 

supplier certification indicating the percent sulfur of the fuel. Fuel use records 

shall be maintained on a monthly basis, in addition to the twelve-month rolling 

total. 

A summary of the BPT analysis for boilers #1 (20.3 MMBtu/hr) and #2 (16.5 

MMBtu/hr) is as follows: 

Based on MEDEP Chapter 103, the BPT emission factors for PM for Boilers 

#1 and #2 shall be 0.12 lb/MMBtu. PM10 emission limits are based on PM 

limits. 
Roy Contin ental Mill, LLC 

An droscoggin County 

Lewist0n, Maine 

A-392-71-E-R 

) 

) 

) 

Departmental 

Findings of Fact and Order 

Air Emission License 

2. BPT for #6 fuel oil is a sulfur content of no greater than 0.5% by weight. 

3. NOx emission limits are based on performance data from similar #6 fuel oil 

fired boilers of this size and age: 

the BPT emission factor for NOx for Boilers #1 and #2 shall be 0.5 lb/MMBtu. 

4. CO and.VOC emission limits are based upon AP-42 data dated 9/98. 

5. Visible emissions from Stack 1 shall not exceed an opacity of 30 percent on a 

6-miriute block average basis, except for no more than two 6-minute block 

averages in. a 3-hour period. 

C. Annual Emission RestrictiOns 

Roy Continental Mill, LLC shall be restricted to the following annual emissions, 

based on a twelve-month rolling total: 

• Total annual facility fuel use shall be limited to 150;000 gallons of #6 fuel oil 

with a sulfur content not to exceed 0.5% by weight. 

Total Allowable Annual Emission for the Facility 

(used to calculate the annual license fee) 

Pollutant Tons/Year 

PM 1.4 

PMi0 1.4 

SO2 5.9 

NOx 5.6 

CO 0.4 

VOC 0.06 

III.AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a minor source shall be determined on a case-by case basis. Based on the 

information available in the file, and the similarity to existing sources, Maine Ambient 

Air Quality Standards (MAAQS) will not be violated by this source.. Based on the total 

facility emissions; Roy Continental Mill, LLC is below the emissions level required for 

modeling and mohitoring. 
Roy Continental Mill, LLC 

Androscoggin County 

Lewiston, Maine 

A-392-71-E-R 

) 

) 

) 

4 

Departmental 

Findings of Fact and Order 

Air Emission License 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicabl.e emission standards, 

will not violate applicable ambient air quality standards in conjunction 

With emissions from other sources. 

The Department hereby grants Air Emission License A:392-71-E=R subject to the 

following conditions: 

Severability. The invalidity or unenforceability of any provision, or part thereof, of this 

License shall not affect the remainder of the provision or any other provisions. This 

License shall be construed and enforced in all respects as if such invalid or unenforceable 

provision or part thereof had been omitted. 

STANDARD CONDITIONS 

(1) Employees .and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(Title 38 MRSA §347-C). 

(2) The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control tec.hnology analysis or the ambient air quality standards analysis, or 

both. 

(4) The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall .submit a description of the program to the Department upon 

request. 
Roy Continental Mill, LLC 

Androscoggin County 

Lewiston, Maine 

A-392-71-E-R 

) 

) 

) 

5 

Departmental 

Findings of Fact and Order 

Air Emission License 

(5) The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing .emissions. 

(8) The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

fora minimum of six (6) years. The records shall be submitted to the Department 

upon written request. 

(9) The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. 

(lO) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

(i) perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

a. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; 

or 

b. pursuant to any other requirement 0f this license to perform stack testing. 
Roy Continental Mill, LLC 

Androscoggin County 

Lewiston, Maine 

A-392•71-E-R 

) 

) 

) 

6 

Departmental 

Findings of Fact and Order 

Air Emission License 

(ii).install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

(iii)submit a written report to the Department within thirty (30) days from date of 

test completion. 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

(i) within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and40 CFR Part 

60 or other method approved or required by the Department; and 

(ii) the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

.the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

(iii)the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

(13) Notwithstanding any other provisions in the State Implementation Plan approVed 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation ofair pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 
Roy Continental Mill, LLC 

Androscoggin County 

Lewiston, Maine 

A-392-71-E-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(15) Upon written .request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. 

SPECIFIC CONDITIONS 

(16) Boilers #1 and #2 

A. Total facility fuel use shall not exceed 150,000 gals/yr, of#6 fuel oil based on 

a twelve-month rolling total. 

B. Roy Continental Mill, LLC shall bum only #6 fuel oil with a sulfur content of 

no greater than 0.5% sulfur by weight. 

Compliance with the above fuel restrictions shall be based on fuel receipts 

from the supplier showing the quantity of fuel delivered and the percent sulfur 

of the fuel. Fuel use records shall be maintained on a monthly basis, in 

addition to the twelve-month rolling total. 

D. Emissions shall not exceed the following: 

Eoui•ment 

Boiler #1 

Boiler #2 

lb/MMBtu 

lb/hr 

lb/MMBtu 

lb/hr 

PM 

0.12 

2.4 

0.12 

2.0 

PM•0 

2.4 

2.0 

SO2 

!0.6 

•8.6 

10.2 

8.3 

CO 

0.7 

0.6 

VOC 

0.1 

0.1 

Eo Visible emissions from Stack 1 shall not exceed an opacity of 30 percent on a 

6-minute block average basis, except for• no more than two 6-minute block 

averages in. a 3-hour period. 

(17) Roy Continental Mill, LLC shall notify the Department within 48 hours and 

submit a report to the Department on a quarterly basis if a malfunction or 

breakdown in any component causes a violation of any emission standard (Title 

38 MRSA §605-C). 
Roy Continental Mill, LLC 

Androscoggin County 

Lewiston, Maine 

A-392-71-E.R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(18) Roy Continental Mill, LLC shall pay the annual air emission license fee within 30 

days of September 30 of each. year. Pursuant to 38 MRSA 353-A, failure to pay 

this annual fee in the stated timeframe is sufficient grounds for the revocation of 

the license under 38 MRSA 341-D, Subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

BY: 

DAVID P. LITTELL, COMMISSIONER 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

The term of this Order Shall be for five (5) years from the signature above. 

Date of initial receipt of application: December 13• 2006 

Date of application acceptance: December 15• 2006 

Date filed with the Board of Environmental Protection: 

This Order prepared by, Peter G. Carleton, Bureau of Air Quality 

2007, 
Franklin Memorial Hospital 

Franklin County 

Farmington, Maine 

A-359-71-G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license renewal application, staff investigation reports 

and other documents in the applicant's file in theBureau of AirQuality, pursuant to 38 

M.R.S.A., Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Franklin Memorial Hospital (FMH) of Farmington, Maine has applied to renew 

their Air Emission License permitting the operation of emission sources 

associated with their healthcare facility. 

.B. Emission Equipment 

FMH is authorized to operate the following equipment: 

Fuel Burning Equipment 

Maximum Maximum 

Equipment Capacity Firing Rate 

0VIMBtu/hr) (•al/hr) 

Boiler #1 8.37 59.79 

Boiler #2 8.37 59.79 

Fuel Type, 

% sulfur 

#2 at 0.35% 

#2 at 0.35% 

Stack # 

1 

2 

Electrical Generation Equipment 

Equipment 

Emergency Unit # 1 

Emergency Unit #2 

Power Output Firing Rate Stack #. 

(kW) (•al/hr) 

300 22.4 #2, 0.35% 

600 43.6 #2, 0.35% 
Frapklin Memorial Hospital 

Franklin County 

Farmington, Maine 

A-359-71-G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Co Application Classification 

The application for FMH does not include the licensing of increased emissions or 

the. installation of new or modified equipment. Therefore, the license is 

considered to be a renewal of current licensed emission units only. 

II. BEST PRACTICAL TREATMENT (BPT) 

mo Introduction 

In Order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT); as defined in Chapter 100 of the Air Regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for existing emissions equipment means that method which controls or 

reduces emissions to the lowest possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emission 

from the source being considered; and 

the economic fe.asibility for the type of establishment involved. 

Bo Boiler #1 and #2 

FMH operates boilers # 1 and #2 each having a maximum design heat input 

capacity of 8.37 MMBtu/hr. Boilers #1 and #2 are Cleaver Brooks boilers 

manufactured in 1974 and are therefore not subject to EPA New Source 

Performance Standards (NSPS) Subpart Dc for boilers with a heat input of 10 

MMBtu/hr or greater and manufactured after June 9, 1989. 

A BPT analysis for Boiler #1 and #2 is listed below: 

MEDEP Chapter 103 contains an applicable PM emission limit. 

MEDEP Chapter 106 contains an applicable fuel sulfur content limit, 

however the BPT limit of 0.35% sulfur by weight is more stringent and 

shall be used. 

The BPT SO2 lb/MMBtu emission factor is derived from a mass balance. 

NOx, CO and VOC lb/1000 gal emission factors are derived from AP-42 

data dated 9/98. 

Visible emissions from Boilers #1 and #2 fuel oil shall not exceed an 

opacity of 20 percent on a six (6) minute block average basis, except for 

no more than one (1) six (6) minute block average in a 3-hour period. 
Franklin Memorial Hospital 

Franklin County 

Farmington, Maine 

A-359-71-G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Co Emergency Units # 1 and #2 

FMH operates two emergency diesel generators with power outputs of 300 kW 

and 600 k W respectively, for• back-up power at the facility. The generators share 

a fuel tank with FMH's boilers. 

A BPT analysis of emergency units #1 and #2 is listed below: 

4. 

5. 

6. 

Since they is only one fuel tank for the facility, .emergency units #1 and #2 

shall fire #2 fuel oil with a sulfur content not to exceed 0.35%. 

Emergency units #1 and#2 shall each be limited to 500 hours of operation 

per year. An operation log shall be kept and an hour meter installed and 

operated to demonstrate compliance. 

MEDEP Chapter 103 contains applicable PM lb/MMBtu emission limits 

for emergency units # 1 and #2. 

The BPT SO2 lb/MMBtu emission factor is derived from a mass balance. 

NOx, CO and VOC lb/MMBtu emission factors are derived from AP-42 

data da•ed 10/96. 

Visible emissions from emergency units #1 and #2 shall not exceed an 

opacity of 20 percent on a six (6) minute block average basis, except for 

no more than two (2) six (6) minute block averages in a 3-hour period. 

"Emergency" is defined in Chapter 1 O0 and throughout this document as: ".., any 

situation arising from sudden and reasonably unforeseeable events beyond the 

control of the source, including acts of God, which situation requires immediate 

corrective action to restore normal operation, and that causes the source to exceed 

a technology based emission limitation under the license, due to unavoidable 

increases in. emissions attributable to the emergency. An emergency shall not 

include noncompliance to the extent caused by improperly designed equipment, 

lack of preventative maintenance, careless or improper operation, or operator 

error." 

Do Annual Emissions and Fuel Limits 

1. FMH shall be limited to the firing of 200,000 gal of#2 fuel oil (12 month 

rolling total) with a sulfur content not to exceed 0.35% by weight. Fuel 

records from the supplier shall be kept documenting quantity received and 

sulfur content to demonstrate compliance. 

2. Em6rgency units #1 and #2 shall each be limit to 500 hours per year of 

operation (12 month rolling total). An operation log shall be kept and an 

hour meter installed and operated to demonstrate compliance. 
Franklin Memorial Hospital 

Franklin County 

Farmington, Maine 

A-359-71-G-R 

) 

) 

) 

4 

Departmental 

Findings of Fact and Order 

Air Emission License 

.The annual facility emissions shall be limited to the following based on a 

12 month rolling total. 

Emission 

Units 

Boilers 

Emergency 

Unit #1 

Emergency 

Unit #2 

Total 

Total Allowable Annual Emission for the Facility 

(used to'calculate the annual license fee) 

Tons/yr 

2.80 

0.09 

0.18 

3.07 

2.80 

0:09 

0.18 

3.07 

SO2 

4.94 

0.26 

0.52 

5•72 

2.00 

3.23 

4.68 

9.91 

 ̧CO 

0.50 

0.70 

1.24 

2.44 

VOC 

0.06 

0.26 

0.13 

0.45 

III.AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a renewal source shall be determined on a case-by case basis. Modeling and 

monitoring are not required for a renewal if the total emissions of any pollutant released 

do not exceed the following: 

Pollutant 

PM 

PM•o 

S02 

NOx 

CO 

Tons/Year 

25 

50 

100 

250 

Based on ihe above total facility emissions, FMH is below the emissions level required for modeling and mbnitoring. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source:. 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 
Franklin Memorial Hospital 

FranMin County 

Farmington, Maine 

A-359-71.G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

The Department hereby grants Air Emission License A-359-71-G-R subject to the 

following conditions: 

(1) 

(2) 

(3) 

(4) 

(6) 

(7) 

Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation• and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(38 MRSA §347-C). 

(8) 

The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [MEDEP Chapter 115] 

Approval to construct shall become invalid if the- source has not commenced 

-construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period .upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [MEDEP Chapter 115] 

The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. [MEDEP Chapter 115] 

The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. [MEDEP Chapter 115] 

The license does not convey any property rights of any sort, or any exclusive 

privilege. [MEDEP Chapter 115] 

The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. [MEDEP Chapter 115] 

The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. IMEDEP Chapter 115] 
FranMin Memorial Hospital 

Franklin County 

Farmington, Maine 

A-359-71-G-R 

) 

) 

) 

6 

Departmental 

Findings of Fact and Order 

Air Emission License 

(9) The..licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee; the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay. 

any condition of the license. [MEDEP Chapter 115] 

(-io) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall' 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions' 

1. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that. equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuant to any other requirement of this license to perform stacl• testing. 

B. install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test completion. 

[MEDEP Chapter 115] 

(12) ff the results of a stack test performed under circumstances representative of.the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

A. within thirty(30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40. CFR Part 

60 or other method approved or required by the Department; and 

B. the days ofviolation shall be presumed to include thedate of st.ack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 
Franklin Memorial Hospital 

Franklin Count3' 

Farmington, Maine 

A-359-71-G-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

[MEDEP Chapter 115] 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA orSection 114(a) of the CAA, any credible-evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [MEDEP Chapter 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 115] 

(15) Upon written request from the Department; the licensee shall establish and 

maintain such. records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at Such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. [MEDEP Chapter 115] 

SPECIFIC CONDITIONS 

(16) Boilers #1 and #2 

A. Total facility fuel use shall not exceed 200,000 gallons/year of #2 fuel oil with 

a maximum sulfur content, not to exceed 0.35% by weight, based on a 12 

month rolling total. Delivery records from the supplier shall be kept 

documenting quantity received and sulfur content for compliance purposes. 

[MEDEP Chapter 115, BPT]. 
FranMin Memorial Hospital 

Franklin County 

Farmington, Maine 

A-359-71-G-R 

) 

) 

) 

8 

Departmental 

Findings of Fact and Order 

Air Emission License 

B. ,Emissions from boilers #1 and #2 shall not exceed the following: [MEDEP 

Chapter. 115, Chapter 103, BPT] 

Equipment 

Boiler #1 

Boiler #2 

lb/MMBtu 

lb/hr 

lb/MMBtu 

lb/hr 

PM 

0.20 

1.67 

PMlo 

1.67 

1.67 

sos 

2.95 

2.95 

NOx 

1.20 

1.20 

CO 

0.30 

0.30 

VOC 

0.03 

0.03 

(17) 

C. Visible emissions from boilers #1 and #2 shall each not exceed 20% opacity based on a •six (6) minute block average basis, except- for no more than one (1) 

six (6) minute block average in a three hour period. [MEDEP Chapter 101 ] 

Emergency Units # 1 and #2 

A. Emergency units #1 and #2 shall fire #2 fuel oil with a sulfur content not to 

exceed 0.35%. [MEDEP Chapter 115, BPT] 

B.. Emergency units #1 and #2 shall each be limited to 500 hours of operation per 

year (12 month rolling total). An operation log shall be kept and an hour 

meter installed and. operated to demonstrate compliance. [MEDEP Chapter 

115, BPT] 

C. Emissions from emergency units #1 and #2 shall not exceed the following: [MEDEP Chapter I 15, Chapter 103, BPT] 

Equipment 

Emergency lb/MMBtu 

Unit #1 

lb/hr 

Emergency 

Unit #2 

lb/MMBtu 

lb/hr 

PM 

0.35 

0.12 

0.70 

PM10 

0.35 

0.70 

SOs 

1:03 

2.06 

Nox 

12.92 

18.72 

CO 

2•78 

4.97 

VOC 

0.53 

D. Visible emissions from emergency units #1 and #2 shall not exceed 20% 

opacity based on a six (6) minute block a•,erage basis, except for no more than 

two (2) six (6) minute block averages in a three hour period. [MEDEP 

Chapter 101 ] 
Franklin Memorial Hospital ) Departmental 

Franklin County ) Findings of Fact and Order 

Farmington, Maine ) Air Emission License 

A-359-71-G-R 9 

(18) FMH shall notify the Department within 48 hours and submit a report to the 

Department on a quarterly basis if • malfunction or breakdown in any component 

causes a violation of any emission standard (Title 38 MRSA §605).. 

(19) Payment of Annual License Fee 

FMH shall pay. the annual air. emission license fee within 30 days of March 31st 

of each year. Pursuant to 38 MRSA §353-A, failure to pay this annual fee .in the 

stated timeframe is sufficient grounds for revocation of the license under 38 

MRSA §341-D, subsection 3. [38 MRSA §353-A• 

DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

BY: 

DAWN R. GALLAGHER, COMMISSIONER 

The term of this license shall be five years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

2004. 

Date of initial receipt of application• 7/13/2004 

Date of application acceptance: 7/27/2004 

Date filed with the Board of Environmental Protection: 

This Order prepared by Jonathan Voisine, Bureau of Air Quality 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N (SM) 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

After review of the air emissions license application, staff investigation reports and other 

documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 M.R.S.A., 

Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

The Air Emission License for Frontier Forge Inc., d/b/a Kingfield Wood Products 

(Frontier Forge) located in Kingfield, Maine expired on October 10, 2005. On 

January 11, 2006 Frontier Forge submitted an application to renew their expired 

license to permit the operation of emission sources associated with their wood 

products manufacturing facility. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Fuel Burning Equipment 

Maximum Maximum 

Equipment Capacity Firing Rate Fuel Type, Control 

(MMBtu/hr) (ton/hr) % sulfur Equipment •iler #3 • 7.9 0.9 .W°°d, negligible multicyclone 

Note: Frontier Forge still has boilers #1 and #2 on-site. However, they have been taken 

out of service, fuel and water supplies have been disconnected, and the doors have been 

barricaded shut. 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

Process Equipment 

Equipment 

Lathes, Saws, Sanding 

Surface Coating 

Drying Kilns* 

Parts Washer 

Pollutant 

PM 

VOC, PM 

Control Equipment 

Baghouse & Cyclone 

Filters 

VOC None 

VOC cover 

*Emissions from the kilns have been calculated to be less than 1 ton/year of 

VOCs. This process is therefore exempt per MEDEP Chapter 115, Appendix B, 

Section B. 1 and is noted for inventory purposes only. 

C. Application Classification 

The previous air emission license for Frontier Forge expired on October 10, 2005. 

A complete application was not submitted on time, therefore Frontier Forge is 

considered to be an existing source applying for an after-the-fact renewal. The 

Department has determined the facility is a minor source and the application has 

been processed through Chapter 115 of the Department's regulations. With the 

emission limit on facility VOC emissions, the facility is license below the major 

source threshold and is considered a synthetic minor. 

II. BEST PRACTICAL TREATMENT (BPT) 

Ao Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for an after-the-fact renewal requires an analysis similar to a Best Available 

Control Technology analysis per Chapter 115 of the Department's regulations. 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

B. Boiler #3 

Boiler #3 is a wood fired boiler used to heat the drying kilns. 

Boiler #3 has a heat ihput of 7.9 MMBtu/hr and is therefore not subject to the 

New Source Performance Standards (NSPS) Subpart Dc for steam generating 

units greater than 10 MMBtu/hr manufactured after June 9, 1989. 

A summary of the BPT analysis for Boiler #3 is the following: 

1. The total fuel use for the facility shall not exceed 7,689 ton/year (12-month 

rolling total) of wood based on a moisture content of 50%. 

2. Frontier Forge shall use the following formula, when necessary, to convert 

fuel use records to 50% moisture: 

Tons Wood at 50% (Tons Wood at M%) x [(100-M)/50] 

Where M the moisture content of the actual wood fired 

3. Frontier Forge shall continuously operate the multicyclone on Boiler #3 when 

Boiler #3 is in operation. 

4. Chapter 103 regulates PM emission limits. However, in this case a BPT 

analysis for PM determined a more stringent limit of 0.3 lb/MMBtu was 

appropriate and shall be used. The PM•0 limits are derived from the PM 

limits. 

5. SO2, NOx, CO, and VOC emission limits are based upon AP-42 data dated 

9/03. 

6. Visible emissions from Boiler #3 shall not exceed 20% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. 

Co Lathes, Saws, and Sanding 

Frontier Forge operates several different sawing, sanding, and wood turning 

operations. BPT for these processes is to vent to a baghouse and cyclone. The 

baghouse, cyclone, and all associated ductwork shall be maintained so as to 

prevent visible emissions in excess of 10% opacity on a six (6) minute block 

average basis, except for no more than one (1) six (6) minute block average in a 

continuous 3-hour period. 

Do Surface Coating 

Frontier Forge operates two paint booths, a silk screening operation, and a tumble 

finishing operation. These processes use various VOC and HAP containing 

finishes. A manometer is used to determine particulate loading across paper 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 4 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

filters. BPT for these processes is the continued use and routine replacement of 

paper filters on the paint booths. A log shall be maintained of filter replacements 

and maintenance done to the paint booths. 

Parts Washer 

The parts washer has a design capacity of 8 gallons and uses mineral spirits as a 

solvent. Records shall be kept of the solvent added and removed. 

Fo Facility Wide Emission Limits 

Frontier Forge shall not exceed an annual emission limit (based on a 12 month 

rolling total) of 35 ton/year for VOCS and 9.9 ton/year for total HAPS. 

Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed an opacity of 20 percent, except for no more than five 

(5) minutes in any 1-hour period. Compliance shall be determined by an 

aggregate of the individual fifteen (15)-second opacity observations which exceed 

20 percent in any one (1) hour. 

Annual Emissions 

Frontier Forge shall be restricted to the following annual emissions, based on a 12 

month roiling total: 

Total Licensed Annual Emission for the Facility 

Tons/year 

(used to calculate the annual license fee) 

Boiler #3 

Process 

Emissions 

Total TPY 

PM 

10.4 

10.4 

PM•o 

10.4 

SO2 

0.9 

NOx 

7.6 

CO 

20.8 

110.4 0.9 7.6 20.8 

VOC 

0.6 

34.4 

35.0 

Total 

HAP 

9.9 

9,9 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

III.AMBIENT. AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a renewal source shall be determined on a case-by case basis. Modeling and 

monitoring are not required for a renewal if the total emissions of any pollutant released 

do not exceed the following: 

Pollutant 

PM 

PM10 

SO2 

NOx 

CO 

Tons/Year 

25 

 ̧25 

50 

100 

250 

Based on the above total facility emissions, Frontier Forge is below the emissions level 

required for modeling and monitoring. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-192-71-H-N subject to the 

following conditions. 

Severability. The invalidity or unenforceability of any provision, or part thereof, of this 

License shall not affect the remainder of the provision or any other provisions. This 

License shall be construed and enforced in all respects as if such invalid or unenforceable 

provision or part thereof had been omitted. 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 6 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(2) 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(Title 38 MRSA §34%C). 

The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [MEDEP Chapter 115] 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [MEDEP Chapter 115] 

(4) The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to .the Department upon 

request. [MEDEP Chapter 115] 

(5) The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. [MEDEP Chapter 115] 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. IMEDEP Chapter 115] 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. [MEDEP Chapter 115] 

(8) The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [MEDEP Chapter 115] 

(9) The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [MEDEP Chapter 115] 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(10) 

(11) 

(12) 

The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 

In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within •ixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuant to any other requirement of this license to perform stack testing. 

B. install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test completion. 

[MEDEP Chapter I 15] 

If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

A. within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other 'method approved or required by the Department; and 

B. the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

C. the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 8 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

demonstration of compliance under normal and representative process and 

operating conditions. 

[MEDEP Chapter 115] 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [MEDEP Chapter 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 115] 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample, such emissions (in accordance with such methods, 

at such-locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. [MEDEP Chapter 115] 

SPECIFIC CONDITIONS 

(16) Boiler #3 

A. Total fuel use for Boiler #3 shall not exceed 7,689 tons/yr at 50% moisture (or 

equivalent) of wood. Records of almual fuel use shallbe kept on a calendar 

basis. [MEDEP Chapter 115, BPT] 

B. Emissions shall not exceed the following: 

Emission Unit Pollutant 

Boiler #3 PM 

lb/MMBtu 

0.30 

origin and Authority 

MEDEP Chapter 115, BPT 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

C. Emissions shall not exceed the following [MEDEP Chapter 115, BPT]: 

(17) 

(18) 

Emission PM 

Unit (lb/hr) 

t •giler #3 2.37 

PM10 

(lb/hr) 

2.37 

SO2 NOx CO VOC 

(lb/hr) (lb/hr) (lb/hr) (lb/hr) 

0.20 1.74 •74 0.13 

Frontier Forge shall continuously operate a multicyclone on the emissions 

from Boiler #3 whenever Boiler #3 is in operation. [MEDEP Chapter 115, 

BPT] 

Visible emissions from Boiler #2 shall each not exceed 20% opacity on a six 

(6) minute block average, except for no more than two (2) six (6) minute 

block averages in a continuous 3-hour period. [MEDEP Chapter 115, BPT] 

Lathes, Saws, and Sanding Operations 

Particulate emissions from these processes shall be vented through a baghouse 

and cyclone. All components of the baghouse, cyclone, and associated 

ductwork shall be maintained so as to prevent leaks. 

[MEDEP Chapter 115, BPT] 

Bo Frontier Forge shall keep a log recording the date and location of all bag 

failures as well as all routine maintenance performed on the baghouse. 

[MEDEP Chapter 115, BPT] 

Visible emissions from the baghouse and cyclone shall not exceed 10% on a 6 

minute block average basis, except for no more than one (1) six (6) minute 

block average in a continuous 3-hour period. [MEDEP Chapter 101 

Surface Coating 

Frontier Forge shall continue to use, and shall routinely replace, paper filters on 

the paint booths. Frontier Forge shall maintain a log of filter replacements and 

maintenance done to the paint booths. [MEDEP Chapter 115, BPT] 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 10 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(19) Parts Washer 

Parts washers at Frontier Forge are subject to MEDEP Chapter 130. 

A. Frontier Forge shall keep records of the amount of solvent added to each parts 

washer. IMEDEP Chapter 115, BPT] 

B. The following are exempt from the requirements of Chapter 130 [MEDEP 

Chapter 130]: 

1. Solvent cleaners using less than two liters (68 oz) of cleaning solvent with 

a vapor pressure of 1.00 mmHg, or less, at 20 C (68 F); 

2. Wipe cleaning; and, 

3. Cold cleaning machines using solvents containing less than or equal to 5% 

VOC by weight. 

The following standards apply to remote reservoir cold cleaning machines that 

are applicable sources under Chapter 130. 

1. Frontier Forge shall attach a permanent conspicuous label to each unit 

summarizing the following operational standards [MEDEP Chapter 130]: 

(i) Waste solvent shall be collected and stored in closed containers. 

(ii) Cleaned parts shall be drained of solvent directly back to the cold 

cleaning machine by tipping or rotating the part for at least 15 

seconds or until dripping ceases, whichever is longer. 

(iii) Flushing of parts shall be performed with a solid solvent spray that is 

a solid fluid stream (not a fine, atomized or shower type spray) at a 

pressure that does not exceed 10 psig. Flushing shall be performed 

only within the freeboard area of the cold cleaning machine. 

(iv) The cold cleaning machine shall not be exposed to drafts greater than 

40 meters per minute when the cover is open. 

(v) Sponges, fabric, wood, leather, paper products and other absorbent 

materials shall not be cleaned in the degreaser. 

(vi) When a pump-agitated solvent bath is used, the agitator shall be 

operated to produce no observable splashing of the solvent against 

the tank walls or the parts being cleaned. Air agitated solvent baths 

may not be used. 

(vii) Spills during Solvent transfer shall be cleaned immediately. Sorbent 

material shall be immediately stored in covered containers. 

(viii) Work area fans shall not blow across the opening of the degreaser 

unit. 

(ix) The solvent level shall not exceed the fill line. 

2. The remote reservoir cold cleaning machine shall be equipped with a 

perforated drain with a diameter of not more than six inches. [MEDEP 

Chapter 130, BPT] 

Co 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 11 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(20) Facility Wide Emission Limits 

mo Frontier Forge shall not exceed a facility wide emission limit of 35.0 ton/year 

for VOCS, based on a 12 month rolling total. Compliance shall be 

demonstrated by recordkeeping which includes amount and VOC content of 

each finish used. IMEDEP Chapter 115, BPT] 

Bo Frontier Forge shall not exceed a facility wide emission limit of 9.9 ton/year 

for total HAPS, based on a 12 month rolling total. Compliance shall be 

demonstrated by recordkeeping which includes amount and HAP content of 

each finish used. [MEDEP Chapter 115, BPT] 

(21) Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed an opacity of 20%, except for no more than five (5) 

minutes in any 1-hour period. Compliance shall be determined by an aggregate of 

the individual fifteen (15)-second opacity observations which exceed 20 percent 

in any one (1) hour. [MEDEP Chapter 101] 

(22) Frontier Forge Shall notify the Department within 48 hours and submit a report to 

the Department on a quarterly basis if a malfunction 0r breakdown in any 

component causes a violation of any emission standard (Title 38 MRSA §605). 

(23) Annual Emission Statement 

In accordance with MEDEP Chapter 137, the licensee shall annually report to the 

Department the information necessary to accurately update the State's emission 

inventory by means of: 

1) A computer program and accompanying instructions supplied by the 

Department; 

or 

2) A written emission statement containing the information required in 

MEDEP Chapter 137. 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 12 

Departmental 

Findings Of Fact and Order 

Air Emission License 

After-the-Fact 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 

The emission statement must be submitted by July or as otherwise 

specified in Chapter 137. 

(24) Air Toxics Emission Statement 

If Frontier Forge exceeds the thresholds for HAPs listed in Appendix A of 

MEDEP Chapter 137 in an inventory year, in accordance with MEDEP Chapter 

137 the licensee shall report, no later than July 1 every three years (2005, 2008, 

2011, etc.) or as otherwise stated in Chapter 137, the information necessary to 

accurately update the State's toxic air pollutants emission inventory by means of a 

written emission statement containing the information required in MEDEP 

Chapter 137. 

Reports and questions on the Air Toxics emissions inventory portion should be 

directed to: 

Attn: Toxics Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437. 
Frontier Forge Inc., 

d/b/a Kingfield Wood Products 

Franklin County 

Kingfield, Maine 

A-192-71-H-N 13 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(25) Payment of Annual License Fee 

Frontier Forge shall pay the annual air emission license fee within 30 days of June 

30 th of each year. Pursuant to 38 MRSA §353-A, failure to pay this annual fee in 

the stated timeframe is sufficient grounds for revocation of the license under 38 

MRSA §341•D, subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

DAY OF 2006. 

BY: 

DAVID P. LITTELL, COMMISSIONER 

The term of this license shall be fiv e (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: 1/11/06 

Date of application acceptance: 1/11/06 

Date filed with the Board of Environmental Protection: 

This Order prepared by Lynn Ross, Bureau of Air Quality. 
Grand Summit Resort Hotel 

Oxford County 

Newry, Maine 

A-946-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

After review of the air emissions license application, staff investigation reports and other 

documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 M.R.S.A., 

Section 344. and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Grand Summit Resort Hotel (GSRH) located in Newry, Maine has applied for an 

Air Emission License permitting the operation of existing emission sources 

associated with their hotel and conference center. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Fuel Burning Equipment 

Equipment 

B. oiler #1 

Boiler #2 

Boiler #3 

Boiler #4 

Maximum 

Capacity 

(MMBtu/hr} 

4.7 

2.4 

1.5 

1.5 

Maximum 

Firing Rate 

(•al/hr) 

33.5 

17.4 

10.4 

10.4 

Fuel Type 

#2 fuel oil 

#2 fuel oil 

#2 fuel oil 

#2 fuel oil 

Stack # 

C. Application Classification 

GSRH is classified as an existing source that is applying for its first air emission 

license, after the fact. The Department has determined the facility is a minor 

source and the application has been processed through Chapter 115 of the 

Department's regulations. 
Grand Summit Resort Hotel 

Oxford County 

Newry, Maine 

A-946-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

II. BEST PRACTICAL TREATMENT (BPT) 

A• Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defiried in Chapter 100 of the Department regulations: Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources, located in designated non-attainment areas. 

BPT for new sources and modifications requires a demonstration that emissions 

are receiving Best Available Control Technology (BACT), as defined in Chapter 

100 of the Department's regulations. BACT is a top-down approach to selecting 

air emission controls considering economic, environmental and energy impacts. 

B. Boilers 

Boilers #1, #2, #3, and #4 are used for facility heating and hot water needs. 

NSPS requirements 

The boilers each have a maximum heat input less than 10 MMBtu/hr and are 

therefore not subject to the New Source Performance Standards (NSPS) Subpart 

Dcfor steam generating units greater than 10 MMBtu/hr manufactured after June 

9, 1989. 

A summary of the BACT analysis for Boilers #1, #2, #3, and #4 is the following: 

1. The total fuel use for Boilers #1, #2, #3, and #4.shall not exceed 100,000 

gal/year of #2 fuel oil. 

2. The SO2 emission limits are based on the firing of fuel which meets the 

criteria in ASTM D396 for #2 fuel oil. 

3. Chapter 103 regulatesPM emission limits for Boiler #1. The PM•0 limits and 

the PM limits for Boilers #2, #3, and #4 are d•rived from Chapter 103. 

4. NOx emission limits are based on data from similar #2 fired boilers of this size 

and age. 

5. CO andVOC emission limits are based upon AP-42 data dated 9/98. 

6. Visible emissions from the boilers shall each not exceed 20% opacity on a six 

(6) minute block average, except for no more than one (1) six (6) minute 

block average in a continuous 3-hour period. 
Grand Summit Resort Hotel 

Oxford County 

Newry, Maine 

A-946-71-A-N 3 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

C. Annual Emissions 

GSRH shall be restricted to the following annual emissions: 

Total Licensed Ann ual Emission for the Facility 

Tons/year 

(usedto calculate the annual license fee) 

PM PMlo SO2 NO:• 

Boilers (total) 0.6 0.6 3.5 2.1 

Total TPY 0.6 0.6 3.5 2.1 

CO VOC 

0.3. 0.1 

0.3 0.1 

III.AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses required for a minor new source shall be determined on a case-by case basis. 

Based on the information available in the file, and the similarity to existing sources, 

Maine AmbientAir Quality Standards (MAAQS) will not be violated by this source. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction with emissions from other sources. 

The Department hereby grants Air Emission License A-946-71-A-N subject to the 

following conditions. 

Se+erability. The invalidity or unenforceability of any provision, or part thereof, of this 

License shall not affect the remainder of the provision or any other provisions. This 

License shall be construed and enforced in all respects as if such invalid or unenforceable 

provision or part thereof had been omitted. 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 
Grand Summit Resort Hotel 

Oxford County 

Newry, Maine 

A-946-71-A-N 

Departmental 

Findings of Fact an d Order 

Air Emission License 

4 After•th e-Fact 

deems necessary for the purpose of performing tests, collecting samples, conducting inspections, or examining and copying records relating to emissions 

(Title 38 MRSA §347-C). 

The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115.- IMEDEP Chapter 115] 

(2) 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (!8) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control .technology analysis or the ambient air quality standards analysis, or 

both. [MEDEP Chapter 115] 

(4) The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive dust, and shall submit a description of the program to the Department upon 

request. [MEDEP Chapter 115] 

The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M. R.S.A. § 353. [MEDEP Chapter 115 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. [MEDEP Chapter 115] 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice forminimizing emissions. [MEDEP Chapter 115] 

(8) The licensee shall maintain sufficient records to accurately document compliance with emission standards and license conditions and shall maintain-such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [MEDEP Chapter 115] 

(9) The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned changes or anticipated noncompliance by the licensee, or the filing of an 

application .by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [MEDEP Chapter 115] 
Grand Summit R•sort Hotel 

Oxford County 

Newry, Maine 

A-946-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(10) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 

(11) In accordance with-the DePartment's air emission compliance test protocol and 40 CFR Part 60 or other method approved Or required by the Department, the 

licensee shall: 

A. perform, stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within •ixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of. compliance with emission 

standards or license conditions; or 

2. pursuant to .any other requirement of this license to perform stack testing. B. install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test comPletion. 

[MEDEP Chapter 115] 

02) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

A. within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under-circumstances representative of the facility's normal process and operating conditions and in accordance 

with the Department's air emissi on compliance test protocol and 40 CFR Part 

60 or othermethod approvgd or required by the Department; and 

B. the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the ex•tent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

C. the licensee may, upon the approval of the Department following the 

successful demonstration .of compliance at alternative load conditions, operate under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and operating conditions. 

[MEDEP Chapter 115] 
Grand Summit Resort Hotel 

Oxford County 

Newry, Maine 

A-946-71-A-N 6 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(13) Notwithstanding any other provisions in the State Implementation Plan approved by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose-of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [MEDEP Chapter 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

,other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two"(2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 15] 

(15) Upon written request from the Department, the licensee shall establish and 

maintain s•uch records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with. such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably require to determine the licensee's compliance status. [MEDEP Chapter 115] 

SPECIFIC CONDITIONS 

(16) Boilers 

A. Total fuel use for Boilers #1, #2, #3, and #4 shall not exceed 100,000 gal/yr of 

#2 fuel oil. Compliance shall be demonstratedby fuel records from the 

supplier showing the quantityand type of fuel delivered. Records of annual 

fuel use shall be kept. [MEDEP Chapter 115, B•kCT] 

B. Emissions shall not exceed the following: 

Emission Unit Pollutant lb/MMBtu Origin and Authority 

Boiler #1 PM 0.08 MEDEP Chapter 115, BACT 
Grand Summit Resort Hotel 

Oxford County 

Newry, Maine 

A-946-71-A-N 

(17) 

(18) 

Departmental 

Findings of Fact and Order 

Air Emission License 

7 After-the-Fact 

Emissions shall not exceed the following [MEDEP Chapter 115, BACT]: 

Emission 

Unit 

Boiler #1. 

Boiler #2. 

Boiler #3 

Boiler #4 

PM 

0b/hr) 

0.38 

0.19 

0.12 

0.12 

PM10 

(lb/hr) 

0.38 

0.i9 

0.12 

0.12 

SO2 

(lb/hr) 

2.36 

1.22 

0.73 

0,73 

NOI 

(lb/hr) 

1.41 

0.73 

0.44 

0.44 

CO VOC 

(lb/hr) (lb/hr) 

0.17 0.01 

0..09 0.01 

0.05 0.01 

0.05 0.01 

Visible emissions from Boilers #1, #2, #3, and #4 shall each not exceed 20% 

opacity on a six (6) minute block average, except for no more than one (1) six 

(6) minute block average in a continuous 3-hour period. [MEDEP Chapter 101] 

GSRH shall notify the Department within 48 hours and submit a report to .the 

Department on a quarterly basis if a malfimction or breakdown in any component 

causes a violation of any emission standard (Title 38 MRSA §605). 

Payment of Annual License Fee 

GSRH shall pay the annual air emission license fee within 30 days of August 31 st. 

of each year. Pursuant to'38 MRSA §353-A, failure to pay this annual•fee in the 

stated timeframe is sufficient grounds for revocation of the license under 38 

MRSA §34.1-D, subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

DAY OF 2006. 

BY: 

DAVID P. LITTELL, COMMISSIONER 

The term of this license shall be five (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: 6/14/06 

Date of application acceptanCe: 6/23/06 

Date filed with the Board of Environmental Protection: 

This Order prepared by Lynn Ross, Bureau of Air Quality. 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

) 

) 

) 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license renewal application, staff investigation reports 

and other documents in the applicant's file in the Bureau of Air Quality, pursuant to ,38 

M.R.S.A., Section.344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Mid Coast Hospital of Brtmswick, Maine has applied to renew their Air Emission 

License permitting the operation of emission sources associated with their health 

care facility. 

B. Emission Equipment 

Mid Coast Hospital is authorized to operate the following equipment:: 

Fuel Burning Equipment 

Equipment 

Boiler #1 

Boiler #2 

Boiler #3 

Unit #4 (air make-up) 

Boiler #4 

Boiler #5 

Maximum 

Capacity, 

(MMBtu/hr} 

1046 

10.46 

10.46 

2..5 

1.0 

Fuel Type, 

% sulfur 

#2 oil, 0.5% 

Natural Gas 

#2 oil, 0.5% 

Natural Gas 

#2 oil, 0.5% 

Natural Gas 

Propane 

Natural Gas 

Propane 

Natural Gas 

Propane 

Natural Gas 

Maximum 

Firing ,Rate 

74.7 gal/hr 

10155 scf/hr 

74.7 gal/hr 

10155 scf/hr 

74.7 gal/hr 

10155 scf/hr 

26.6 gal/hr 

2427.2 scf/hr 

10.6 gal/hr 

970.9 scf/hr 

10.6 gal/hr 

970.9 scf/hr 

Stack # 

1 

1 

3 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Electrical Generation Equipment 

Equipment 

Emergency 

Generator # 1 

Power Output Fuel Type 

(kW) % Sulfur 

1250 Diesel fuel,' 0.05% 

Maximum 

Firin• Rate Stack # 

82.5 (gai/hr) 4 

C. Application ClasSification 

The application for Mid Coast Hospital does not include the licensing of increased 

emissions or the installation of new or modified equipment. Therefore, the 

license is considered to bea renewal of•current licensed emission units only. This 

source is determined to be a minor source and has been processed as such. 

II. BEST PRACTICAL TREATMENT (BPT) 

A. Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for existing emissions equipment means that method which controls or 

reduces emissions to the lowest possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emissions 

from the source being considered; and 

the economic feasibility for the type of establishment involved. 

B. Boilers #1, #2 and #3 

Mid Coast Hospital operates Boilers # 1, #2 and #3 primarily for facility hot water 

and heating needs. Boilers # 1, #2 and #3 have maximum heat input capacities of 

10.46 MMBtu/hr each firing #2 fuel oil. All three boilers were manufactured •and 

installed in 2000 and were subject to BACT as well as EPA New Source 

Performance Standards (NSPS) Subpart Dc (Standards of Performance for Small 

Industrial-Commercial-institutional Steam Generating Units applicable to boilers 

with a heat input of greater than 10 MMBtu/hr and manufactured after 

June 9, 1989). Th.e applicable requirements are included in the following: 

1. Standard for sulfur dioxide: 40 CFR Part 60, Subpart Dc, section 60.42c, 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

2. Compliance and performance test meth0dg and procedures for sulfur dioxide: 

40 CFR Part 60, Subpart Dc, section 60.44c, 

3. Reporting and record keeping requirements: 40 CFR Part 60, Subpart Dc, 

section 60.48c. 

As p.er NSPS, Subpart Dc, Mid Coast Hospital shall be restricted to firing #2 fuel 

oil with a sulfur content of no greater than 0.5% sulfur by weight, based on a 30 

day rolling average, in the three boilers. Compliance with this restriction shall be 

based on supplier certification containing the follOwing information: 

a. name of the supplier; and 

b. statement from the supplier that the oil complies withthe specifications under 

the definition of distillate oil. 

Mid Coast Hospital's current license restricts Boilers. #1, #2 and #3 tofiring no 

greater than 1,000,000 gallons of #2 fuel oil in the three boilers combined 

annually. Boilers #1, #2 and #3 are also currently licensed to fire natural gas with 

no .restriction given in the current license. In an effort to allow the facility the 

flexibility to make good economic choices as to which of the two licensed fuels to 

use (#2 fuel oil or natural gas) and at the same time maintain the current licensed 

allowed emissions from the three boilers, heat input into the three boilers will be 

restricted. In the future, Mid Coast Hospital shall be restricted to an annual heat 

input in Boilers #1, #2 and #3 combined of 140,000 MMBtu/yr based on a 

twelve-month rolling total. This is the equivalent heat input of 1,000,000 gallons 

of #2 fuel oil. Heat input shall be calculated using the following conversion 

factors: 

1. 140•000 btu per gallon of#2 fuel oil, 

2. 1030 btu per scf of natural gas, 

In order to demonstrate compliance with the annual heat input restriction and the 

sulfur content restriction, Mid Coast Hospital shall maintain a fuel use log, which 

shall include the fuel oil consumption, heat input calculations and the NSPS 

required supplier certification. 

A summary of the BACT/BPT analysis for boilers #1 (10.46 MMBtu/hr), 

#2 (10.46 MMBtu/hr) and#3 (10.46 MMBtu/hr) is as follows: 

1. NSPS, Subpart Dc requires the use of fuel oil with a sulfur content of no 

greater than 0.5% by weight. 

2. The PM/PM•0 limits are derived from Chapter 103. 

3. NOx, CO and VOC emission limits are base d upon AP-42 data dated 9/98 for 

the combustion of #2 fuel oil and 10/96 for the c•mbustion of natural gas. 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

) 

) 

) 

4 

Departmental 

Findings of Fact and Order 

Air Emission License 

4. Visible emissions from Stack #1 are subject to Chapter 101 of the Air 

Regulations and shall be restricted to the following: 

ao Visible emissions from stack #1, during periods when only one of the 

three boilers is operational and is firing natural gas, shall not exceed 10% 

opacity on a 6-minute block average except, for no more than one 

6-minute block average in a 3-hour period. 

bo Visible emissions from stack #1, during periods when only one of the 

thre6 boilers is operational and is firing #2 fuel oil, shall not exceed 20% 

opacity on a 6-minute block average except, for no more than two 

6-minute block averages in a 3-hour period. 

Co Visible emissions from stack #1, during, periods when more than one of 

the three boilers is operational and firing either fuel, shall not exceed 30% 

opaCity on a 6-minute block average except, for no more than three 6= 

minute block averages in a 3-hour period. 

Annual emission restriction calculations for B'oilers #1, #2 and#3 are based on 

theworst case scenario of firing only #2 fuel oil. 

C. Unit #4 (make-up air unit) 

Mid Coast Hospital utilizes a small hot air make-up unit rated at 2.5 MMBtu/hr 

firing either propane or natural gas. Unit #4 has a maximum heat input capacity below the NSPS applicability threshold and is therefore not subject-to EPA's 

NsPs Subpart Dc 

A summary of the BPT analysis for Unit #4 is as follows: 

1. Unit #4 is subject to Chapter 103 (Fuel Burning Equipment Particulate 

Emissions 'Standards), however BPT for PM/PM•0 in this license is more 

restrictive. BPT for PM/PM•0 for Unit #4 is 0.05 lb/MMBtu. 

2. SO2, NO,,, CO and VOC emission limits are based upon AP-42 data dated 

9/98 for propane combustion 7/98 for natural gas combustion. 

3. Visible emissions from Stack #2 are subject to Chapter 101 of the Air 

Regulations: 

ViSible emissions from stack #2 shall not exceed 10% opacity on a 6-minute 

block average except, for no more than one 6-minute block average in a 

3-hour period. 

Unit #4 annual emission restriction calculations are based on the worst case 

scenario of either propane or natural gas for each criteria pollutant. 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

) 

) 

) 

5 

Departmental 

Findings of Fact and Order 

Air Emission License 

D. Boilers #4 and #5 

Mid Coast •Hospital makes use of Boilers #4 and #5 primarily for facility hot 

water and heating needs for the Medical. Office Building. Boilers #4 and #5 have 

maximum design heat input capacities of 1.0 MMBtu/hr each firing either natural 

gas or propane. Both units have maximum heat input capacities below the NSPS 

applicability threshold and are therefore not subject to EPA's NSPS Subpart Dc 

A summary of the BPT analysis for Boiler #4 and #5 are as,follows: 

1. Boilers #4 and #5 are subject to Chapter 103 (Fuel Burning Equipment 

Particulate Emissions Standards), however BPT for PM/PM •0 in this license is 

more restrictive. BPT for PM/PM10 for Unit #4 is 0.05 lb/MMBtu. 

2. SO2, NOx, CO and VOC emission limits are based upon AP-42 data dated 

9/98 for propane combustion 7/98 for natural gas combustion. 

3. Visible emissions from Stack #3 are subject to Chapter 101 of the Air 

Regulations: 

Visible emissions from stack #3 shall not exceed: 10% opacity on a 6-minute 

block average except, for no more than one 6-minute block average in a 

3-hour period. 

Annual emission restriction calculations for Boilers #4 and #5 are based on the 

worst case scenario of either propane or natural gas for each criteria pollutant. 

E. Emergency Diesel #1 

Mid. Coast Hospital utilizes a Caterpillar 3512 TA generator set, designated 

Emergency Diesel #1, to provide power to vital electrical systems at Mid Coast 

Hospital during periods of emergency. This unit shall be restricted to firing of a 

low sulfur diesel fuel with a sulfur content of no greater than 0.05% sulfur by 

weight. 

As previously licensed, Mid Coast Hospital is limited to operating the emergency 

diesel unit no greater than 300 hours per year based on a twelve-month rolling 

total. In addition, the emergency diesel generator will be operated only when 

normal testing procedures, as recommended by the manufacturer, are being 

performed .or in case of an emergency as defined in Chapter 100 of the 

Department Regulations. In order to demonstrate compliance with the hours of 

operation restrictions, Mid Coast Hospital shall install, maintain and operate an 

hour meter on the generator unit within 6 months of the signing of this license. 

Mid Coast Hospital shall maintain a log of Emergency Generator #1 operations 

with entries of the dates, times, hour meter reading and reason of operation for 

the generator shall be kept. 
Mid CoastHospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

The following is the definition of "Emergency" for MEDEP Chapter 115 

purposes as per MEDEP Chapter 100: 

"... any situation arising from sudden and reasonably unforeseeable events beyond the control of 

the source, including acts of God, which situation requires immediate corrective action to restore 

nOrmal operation, and that causes the source to exceed a technology based emission limitation 

under the license, due to unavoidable increases in emissions attributable to the emergency. An 

emergency shall not include noncompliance to the extent caused by improperly designed 

equipment, lack of preventative maintenance, careless or improper operation, or operator error." 

By definition, a diesel used for load shedding purposes (also known as a 

"Dispachable LoadGenerators").is not considered an "Emergency Generator". 

A summaryof the BPT analysis for EmergencY Diesel Generator #1 is as follows: 

1. The PM/PM•0 limits are derived from Chapter 103. 

2. SO2, NO×, CO' and VOCemission limits are based upon AP-42 data dated 

10/96 for diesel engines of greater than 600 HP. 

3. Visible emissions from Stack #4 are subject to Chapter 101 of the Air 

Regulations: 

Visible emissions from stack #4 shall not exceed 20% opacity on a 6-minute 

block average except, for no more than two 6-minute block averages in a 

3-hour period. 

F. Annual Emission Restrictions 

Mid Coast Hospital shall be assessed fees based on the following annual 

emissions, based on a twelve-month rolling total: 

Pollutant Tons/Year 

PM 6.6 

PM10 6.6 

SO2 35.9 

NOx 9.4 

CO 5.2 

VOC 1.0 

III.AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a renewal source shall be determined on a case-by case basis. Based on the 

above total facility emissions, Mid Coast Hospital is belowthe emissions level required for modeling and monitoring. 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

) 

) 

) 

7 

.Departmental 

Findings of Fact and Order 

Air Emission•License 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-763-71-C-R subject to the 

following conditions: 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions Units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(Title 38 MRSA §347-C). 

(2) The licensee shall acquire a new ,or amended air emission license prior to 

commencing construction of amodification, unless specifically provided for in 

Chapter 115. 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may Condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. 

(4) The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive dust, and shall submit a description of the program to the Department upon 

request. 

(5) The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A_ §353. 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. 
Mid Coast Hospithl 

Cumberland County 

Brunswick, Maine 

A-763-71,C-R 

) 

) 

) 

8 

Departmental 

Findings of Fact and Order 

Air EmissionLicense 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. 

(8) The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and Shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. 

(9) The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. 

(10) The licens6e may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR. Part 60 or other method approved or required by the Department, the 

licensee shall: 

(i) perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

ao within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating, parameters, 

staff inspection, air monitoring or other cause indicate to the Departmenf 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

b. pursuant to any other requirement of this license to perform stack testing. 

(ii) install or make pr6visions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

(iii)submit a written report to the Department within thirty (30) days from date of 

test completion. 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(12) If the results, of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

(i) within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 

(ii) the day• of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

(iii)the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

(13) Notwithstarlding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2). days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

) 

) 

) 

10. 

Departmental 

Findings of Fact and Order 

Air Emission License 

SPECIFIC CONDITIONS 

(16) Boilers # 1, #2 and #3 

A. Mid Coast .Hospital shall be licensed to fire either #2 fuel oil or natural gas in 

Boilers #1, #2 and #3. 

B. Mid Coast Hospital shall be restricted to an annual heat input in Boilers #1, #2 

and #3 combined of 140,000 MMBtu/yr based on a twelve-month rolling total. 

C. New Source Performance Standards (NSPS) 

As per 40 CFR Part 60, Subpart Dc, section 60.42c: Standard for sulful 

dioxide, Mid Coast Hospital shall be restricted to firing #2 fuel oil with a 

sulfur content of no greater than 0.5% sulfur by weight, based on a 30 day 

rolling average, in the three boilerS. Compliance with this restriction shall be 

based on supplier certification containing the following information: 

a. name of the supplier; and 

b. statement from the supplier that the oil complies with the-specifications 

under the definition of distillate oil 

Mid Coast Hospital shall comply with the requirements of 40 CFR Part 60, 

Subpart Dc, section 60.44c: Compliance and performance test methods and 

procedures for sulfur dioxide, 

3. Mid Coast Hospital shall comply with the requirements of 40 CFR Part 60, 

Subpart Dc, section 60.48c: Reporting and record keeping requirements. 

Mid Coast Hospital shall maintain a fuel use log for Boilers #1, #2 and #3, which 

shall include the fuel oil consumption, heat input calculations and the NSPS 

required supplier certification. The fuel use log shall be maintained on a monthly and a twelve-month rolling total basis 

E. Emissions from Boilers #1, #2 and #3 each shall no'exceed the following: 

Fuel Type PM 

lb/MMBtu 0.08 

#2 Fuel Oil lb/hr 0.8 

lb/MMBtu 0.05 

Natural Gas lb/hr 0.5 

PM10 SO2 NOx CO 

0.8 1.5 

0.5 

5.3 

0.006 1.0 

0.4 

0.8 

VOC 

0.04 

0.06 
Mid Coast Hospital 

CumberlandCounty 

Brunswick, Maine 

A-763-71-C-R 

) Departmental 

) Findings of Fact and Order 

) Air Emission License 

11 

F. Visible emissions. 

Visible emissions from stack #1, dhring periods when only one of the three 

boilers is operational and is firing natural gas, shall not exceed 10% opacity 

on a 6-minute block average except, fbr no more than one 6-minute block 

average ina 3=hour period. 

Visible emissions from stack #1, during periods when only one of the three 

boilers is operational and is firing #2 fuel oil, shall not exceed 20% opacity on 

a 6-minute block average except, for no more than two 6-minute block 

averages in a 3-hour period. 

Co Visible emissions fromstack #1, during periods when more than one of the 

three boilers is operational and firing either fuel, shall not exceed 30% opacity 

on a 6-minute block average except, for no more than three 6-minute block 

averages in a 3-hour period. 

(17) Unit #4(make-up air unit) 

A. Mid Coast Hospital shall be licensed to fire either natural gas or propane in 

Unit #4 (make-up air unit). 

B. Emissions from Unit #4 shall notexceed the following:. 

Fuel Type PM. 

Natural Gas lb/hr 0.1 

Propane lb/hr 0.1 

PM10 SO2. 

0.002 

0.04 

NOx CO 

0.2 0.2 

0.4 0.05 

VOC 

0,01 

0•01 

C. Visible emissions from stack #2 shall not exceed 10% opacity on a 6-minute 

block average except, for no more than one 6-minute block average in a 

3-hour period. 

(18) Boilers #4 and #5 

A. Mid Coast Hospital shall be licensed to fire either natural gas or propane in 

Boilers #4 and #5. 

B. Emissions from Boilers #4 and #5 each shall not exceed.the following: 

Fuel Type PM 

Natural Gas lb/hr 0.05 

Propane lb/hr 0.05 

PM•o. SO2 

0.05 0.001 

0.05 0.02 

NOx CO VOC 

0.1 0.08 0.01 

0.2 0.02 0.01 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

) 

) 

) 

12 

Departmental 

Findings of Fact and Order 

Air Emission License 

Visible emissions from stack #3 shall not exceed 10% opacity on a 6-minute 

block average except, for no more than one 6-minute block average-in a 

3-hour period. 

(19) Emergency Generator # 1 

Mid Coast Hospital shall fire only diesel fuel oil with a maximum sulfur 

content of 0.05% by weight in Emergency Generator #1. Compliance shall be 

based on fuel receipts from the supplier showing the quantity of fuel delivered 

and percent sulfur of the fuel. 

Bo The Emergency Diesel Generator shall be limited to 300 hours per year of 

operation, based on a 12 month rolling total. An hour meter shall be installed, 

maintained and operated on Emergency Generator #1. 

Co Emergency Generator #1 shall be operated only when normal testing 

procedures, as recommended by the-manufacturer, are being performed or in 

case of an emergency as defined in Chapter 100 of the Department 

Regulations. 

A log documenting the dates, t•mes, meter readings and reason of operation 

for the generator shall he kept. The log shall include receipts from the fuel oil 

supplier indicating fuel oil sulfur content. 

E. Emissions from the emergency diesel generator shall not exceed the 

following: 

Fuel Type PM 

Emergency lb/MMBtu 0.12 

Generator # 1 lb/hr 1.4 

PM•0 SO2 

1.4 0.6 

NOx 

38.2 

CO VOC 

10.1 4.2 

F. Visible emissions from Stack #4 shall not exceed 20% opacity on a 6:minute 

block average except, for no more than two 6-minute block averages in a 

3-hour period. 

(20) Mid Coast Hospital shall notify the Department within 48 hours and submit a 

report to the Department on a quarterly basis if a malfunction or breakdown •n 

any component causes a violation of any emission standard 

(Title 38 MRSA §605-C). 

(21) Mid Coast Hospital shall pay the annual air emission license fee within 30 days of 

May 31 of each year. Pursuant to 38 MRSA 353-A, failure to pay this annual fee 

in the stated timeframe is sufficient grounds for the revocation of the license 

under 38 MRSA 341-D, Subsection 3. 
Mid Coast Hospital 

Cumberland County 

Brunswick, Maine 

A-763-71-C-R 

) 

) 

13 

Departmental 

Findings of Fact and Order, 

Air Emission License 

DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

BY: 

DAWN R. GALLAGHER, COMMISSIONER 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

The term of this Order shall be for five (5) years from the signature above. 

Date of initial-receipt of application: January 23, 2004 

Date of application acceptance: January 27• 2004 

Date filed with the Board of Environmental Protection: 

This Order prepared by, Peter G. Carleton, Bureau of Air Quality 

2004. 
Blue Hill Memorial Hospital 

Hancock County 

Blue Hill, Maine 

A-543-71-I-R/A 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license application, staff investigation reports and other 

documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 M.R.S.A., 

Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

Introduction 

Blue Hill Memorial Hospital (BHMH) of Blue Hill, Maine has applied to renew 

their Air Emission License permitting the operation Of emission sources 

associated with their healthcare facility. 

BHMH has requested to be licensed to fire #2 fuel oil in.the boilers as an option 

to firing #4 fuel oil for which they were preViously licensed. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Fuel Burnin• Eq 

Maximum Maximum 

Equipment 

Boiler #1 

Boiler #2 

Boiler #3 

Capacity 

(MMBtu/hr) 

2.1• 

4.2 

4.2 

Firing Rate 

(•al/hr) 

14.5 

29.0 

29.0 

uipment 

Fuel Type, 

% sulfur 

#2, #4, 0:5% 

#2, #4, 0.5% 

#2, #4, 0.5% 

Stack # 

1 

1 

1 

Electrical Generation Equipment 

Equipment Power Output Firing Rate Fuel Type• % sulfur Stack # 

(kW) (•al/hr) 

Generator#! •, 180 14.6 #2, 0:05% 2 

Generator #2 .200 16.2 #2, 0.05% 3 

Application Cl.assification 

The application for BHMH does not include the licensing of increased emissions 

or the installation of new or modified equipment. Therefore, the license is 

considered to be a renewal of current licensed emission units only. 

Blue Hill Memorial Hospital 

Hancock County 

Blue Hill, Maine 

A-543-71-I-R/A 

Departmental 

Findings of Fact and Order 

Air Emission License 

II. BEST PRACTICAL TREATMENT (BPT) 

Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. BPT for existing emissions 

equipment means that method which controls or reduces emissions to the lowest 

possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emissions 

from the source being considered; and 

the economic feasibility for the type of establishment_involved. 

Boilers # 1, #2 and #3 

BHMH operates three boilers, all of which were manufactured in 1973. Boilers 

#2 and #3 each have maximum design heat inputs of 4.2 MMBtu/hr, while Boiler 

#1 hasa maximum design heat input of 2.1 MMBtu/hr. The boilers fire #2 or #4 

fuel oil with a maximum sulfur content not to exceed 0,5% by weight. 

The boilers are not subject to the New Source Performance Standards (NSPS) 

Subpart Dc for steam generating units greater than 10 MMBtu/hr manufactured 

after June 9, 1989. 

A summary, of the BPT analysis for Boilers #1, #2 and #3 is the following: 

1. The total fuel use for the facility shall not exceed 150,000 gal/year of #2 or #4 

fuel oil, based on a 12 month rolling total, with a maximum sulfur content not 

to exceed 0.5% by weight. 

2. Chapter 106 regulates fuel sulfur content, however in this case a BPT analysis for SO2 determined a more stringent limit of 0.5% was appropriate and shall 

be used: 

3. Chapter. 103 regulates PM emission limits. The PM10 limits are derived from 

the PM lirriits. 

4. NOx emission limits are based on data from similar fuel oil fired boilers of 

this size and age. 

5. CO and VOC emission limits are based upon.AP-42 data dated 9/98. 

6. Visible emissions from the combined stack serving Boilers #1 #3 shall not 

exceed 30% opacity on a 6-minute block average basis, except for no more 

than two 6-minute block averages in a 3-hour period. 
Blue Hill Memorial Hospital 

Hancock County 

Blue Hill, Maine 

A-543-71oI-R/A 3 

Departmental 

Findings of Fact and Order 

Air Emission License 

Co Emergency. Generators 

BHMH operates two generators for emergency electrical generation. Generator #1 

is rated at. 14.6 gallons/hour (180 kW). Generator #2 is rated at 16.2 gallons/hour 

(200 kW). Both generators fire fuel oil with a maximum sulfur content not to 

exceed 0.05% by weight. 

Both generators are utilized for emergency (as defined below) back-up power, and 

shall each be hmlted to 500 hours of operation per year on a rolling total basis. 

'Emergency' is defined in Chapter 100 and throughout this document as: 

"... any situation arising from sudden and reasonably unforeseeable events beyond the 

control of the source, including acts of God, which situation requires immediate 

corrective action to restore normal operation, and that causes the source to exceed a 

technology based emission limitation under the license, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance 

to the extent caused by improperly designed equipment, lack of preventative 

maintenance, careless or improper operation, or operator error." 

Do 

BPT for Generatorg #1 and #2 is the following: 

1. Generators #1 and #2 shall fire only fuel oil with a maximum sulfur content 

not to exceed 0.05% by weight. 

2. The emergency generators shall each be limited to .500 hr/year of operation 

based on a 12 month rolling total. 

3. Chapter 106 regulates fuel sulfur content, however in this case the BACT 

analysis fo{ SO2 determined a more stringent limit of 0.05% is appropriate and 

shall be used. 

4. PM, NOx, CO, and VOC emission limits are based upon AP-42 data dated 

10/96. 

5. Visible emissions from the_ stack of each emergency generator shall not 

exceed 20% opacity on a 6-minute block average basis, except for no more 

than two 6-minute block averages in a 3-hour period. 

Annual Emissions 

The annual emissions were calculated based on the following: 

The firing of 150,000 gallons of #4 fuel oil in the boilers, with a maximum 

sulfur content not to exceed 0.5% by weight; and 

500 hours of operation each for Generator #1 and #2, each firing #2 fuel with 

a maximum sulfur content not tO exceed 0.05% by weight. 

BHMH shall be restricted to the following annual emissions, based on a 12 month 

rolling total: 

Blue Hill Memorial Hospital 

Hancock County 

Blue Hill, Maine 

A-543-71-I-R/A 4 

Departmental 

Fin dings of Fact and Order 

Air Emission License 

Boilers 

Generator # 1 

Generator #2 

Total TPY 

Total Licensed Annual Emissions for the Facility 

Tons/year 

used to calculate the annual license fee' 

PM 

1.31 

0.07 

0.07 

1.45 

PM10 

1.31. 

1.45 

802 

5.60 

0.03 

0.03 

5.66 

NOx 

3.81 

2.26 

2.5 

8.57 

.CO 

0.38 

0.49 

0.54 

1.41 

VOC 

0.03 

0.18 

0.20 

0.41 

IlL AMBIENT AIR QUALITY ANALYSIS 

AcCording to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a renewal source shall be determined on a case-by case basis. Based on the 

above total facility emissions, BHMH is below the emissions level required for modeling and monitoring. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air-quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-543-71-I-R/A subject to the 

following conditions: 

STANDARD CONDITIONS 

(1) 

(2) 

(3) 

Employees .and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as. the Department 

deems necessary for ,the purpose of performing tests, collecting samples, 

conducting inspections,, or examining and copying records relating to emissions. 

[38 MRSA .§347-C] 

The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [MEDEP Chapter 115] 

Approval to construct shall become invalid ifthe source has not commenced 

,construction within eighteen (18) months after receipt of such approval or if 

construction, is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

Blue Hill Memorial Hospital 

Hancock County 

Blue Hill, Maine 

A-543-71-I-R/A 5 

Departmental 

Findings of Fact and Order 

Air Emission License 

extension is justified, but may condition such extension upon a review of either 

the control 'technology analysis or the ambient air quality standards analysis, or 

both. [MEDEP Chapter 115] 

(4) The licensee shall establish and maintain a Continuing program of best 

management practices forsuppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. [MEDEP Chapter 115] 

(5) The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. [MEDEP Chapter 115] 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. [MEDEP Chapter 115] 

(7) Th6 licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. IMEDEP Chapter 115] 

(8) The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for.a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [MEDEP Chapter 115] 

(9) 

(lO) 

The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [MEDEP Chapter 115] 

The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 

(11) In accordance with the Depa•ment's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 
Blue Hill Memorial Hospital 

Hancock County 

Blue Hill, Maine 

A-543-71-I-R/A 6 

Departmental 

Findings of Fact and Order 

Air Emission License 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuar•t to any other requirement of this license to perform stack testing. 

B. install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appefidix A, and test platforms, if necessary, and other 

accommodations necessary to allow emissiOn testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test completion. 

[MEDEP Chapter 115] 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

A. within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 

B. the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

.there were intervening days during which no violation occurred or that the 

Violation was not continuing in nature; and 

C. the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

[MEDEP Chapter 115] 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA.or Section 114(a) of the CAA, any credible evidence maybe used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requiremen•t., [MEDEP Chapter 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions Of the air emission license. The licensee shall notify.the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes ,result in an increase of emissions. The licensee 

Blue Hill Memorial Hospital 

Hancock County 

Blue Hill, Maine 

A-543-71-I-R/A 

Departmental 

Findings of Fact and Order 

Air Emission License 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 115] 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. [MEDEP Chapter 115] 

SPECIFIC CONDITIONS 

(16) Boilers #1, #2 and #3 

A. Total fuel use for the boilers shall not exceed a total of 150,000 gal/year of #2 

and #4 fuel oil, each with a maximum sulfur content not to exceed 0.5% by 

weight. Compliance shall be demonstrated by fuel receipts and/or records 

from the supplier showing the quantity of fuel delivered and the percent sulfur 

of the fuel. Records of annual fuel use shall be kept on a 12-month rolling 

total basis. [MEDEP Chapter 115, BPT] 

B. Emissions shall not exceed the following: 

Emission Unit 

Boiler #1 

Boiler •#2 

Boiler #3 

Pollutant 

PM 

PM 

lb/MMBtu 

0.12 

0•12 

0.12 

Origin and Authority 

MEDEP, Chapter 103, 

Section 2(B)(1)(a) 

MEDEP, Chapter 103, 

Section 2(B)(1)(a) 

MEDEP, Chapter 103, 

Section 2(B)(1)(a) 

C. Emissions from the boilers shall not exceed the following when firing #4 fuel 

oil [MEDEP Chapter 115, BPT]: 

Emission 

Unit 

Boiler #1 

Boiler #2 

Boiler #3 

PM. 

0b/hr) 

0.26 

0.51• 

0.51' 

PMlo 

(lb/hr) 

0.26 

0.51 

.0.51 

S02 

(lb/hr) 

1.09 

2.17 

2.17 

NOx 

(lb/hr) 

0:74 

1.47 

1.47 

CO 

(lb/hr) 

VOC. 

(lb/hr) 

0.15 

0.15 

0.08 0.01 

0.01 

0.01 
Blue Hill Memorial Hospital 

Hancock County 

Blue Hill, Maine 

A-543-71-I-R/A 

Departmental 

Findings of Fact and Order 

Air Emission License 

D. Emissions from the boilers shall not exceed the following when firir•g #2 fuel 

oil [MEDEP Chapter 115, BPT]: 

(17) 

Emission 

Unit ". 

Boiler #1 

Boiler #2 

Boiler ,#3 

PM 

0b/hr)., 

0.26 

0.51 

0.51 

PM•o 

(lb/hr) 

0.26 

0.51 

0.51 

S02 

(lb/hr) 

1.06 

2.17 

2.17 

NOx 

0b/hr) 

0.63 

1.26 

1.26 

CO_ 

(lb/hr) 

0.08 

0.15 

0.15 

VOC 

(lb/hr) 

0.01 

0.01 

0.01 

Visible emissions from the combined stack serving Boilers #1 #3 shall not 

exceed 30% opacity on a 6-minute block average, except for no more than two 

6-minute block averages in a continuous 3-hour period. [MEDEP Chapter 

101] 

Generators #1 and #2 

A. BHMH shall limit Generators #1 and #2 to 500 hr/year of operation each 

(based on a 12 month rolling total). An hour meter shall be maintained and 

operated ori each generator. [MEDEP Chapter 115, BPT] 

B.. The generators shall be operated for emergency purposes only or for short 

periods to exercise the machines and keep them in oper.ating order. A log 

documenting the date, time, and reason of operation for each emergency 

generator shall b• kept: [MEDEP Chapter 115, BPT] 

C.- Generators #1 and #2 shall fire fuel oilwith a sulfur content not to exceed 

0.05% by weight. Compliance shall be based on fuel receipts and/or records 

from the supplier showing the quantity of fuel delivered and the percent sulfur 

of the fuel. [MEDEP Chapter 115, BPT] 

D. Emissions shall not exceed the following: 

Emission Unit. 

Generator # 1 

Generator #2 

Pollutant 

PM 

PM 

lb/MMBtu 

0.12 

0.12 

Origin and Authority 

MEDEP, Chapter 103, 

Section 2(B)(1)(a) 

MEDEP, Chapter 103, 

Section 2(B)(1)(a) 
Blue Hill Memorial Hospital 

Hancock County 

Blue Hill, Maine 

A-543-71-I-R/A 

Departmental 

Fin dings of Fact and Order 

Air Emission License 

E. Emissions shall not exceed the following [MEDEP Chapter 115, BPT]: 

Fo 

Emission 

Unit 

Generator # 1 

Generator.#2 

PM 

(lb/hr) 

0.25 

0.28 

PMlo 

(lb/hr) 

0,25 

0.28 

SO2 

(lb/hr) 

0.11 

0:12 

NOx 

(Ib/hr) 

9.1 

.10.0 

CO 

(Ib/hr) 

1.95 

2.16 

VOC 

(lb/hr) 

0•72 

0.80 

(18) 

Visible emissions from the stack of each emergency generator shall not 

exceed 20% opacity on a 6-minute block average, except for no more than two 

6-minute block averages in a 3-hour period. [MEDEP Chapter 101 

(19) 

BHMH shall notify the Department within 48 hours and submit a report to the 

Department ona quarterly basis if a malfunction or breakdown in any component 

causes a violation of any emission standard. [38 MRSA §605] 

Payment of Annual License Fee 

BHMH shall pay the annual air emission license fee Within 30 days of August 31 

of each year. Pursuant to 38 MRSA 353-A, failure to pay this annual fee in the 

stated timeframe is sufficient grounds for revocation of the license under 38 

MRSA 341-D, subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

2004. 

BY: 

DAWN R, GALLAGHER, COMMISSIONER 

The term of this license shall be •five (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: April 20, 2004 

Date of application acceptance: April 29, 2004 

Date filed with the Board of Environmental Protection: 

This Order prepared by Rachel E. Pilling, Bureau of A!r Quality. 

Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license renewal application, staff investigation reports 

and other documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 

M:R.S.A., Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Northeastern Log Homes, Inc. (Northeastern) of Kenduskeag, Maine has applied 

to renew their Air Emission License permitting the operation of emission sources 

associated with their Eastern White Pine Log Home facility. 

B. Emission Equipment 

Northeastern is authorized to operate the following equipment: 

Wood Fired Boiler 

Maximum Maximum 

Equipment Capacity Firing Rate 

(MMBtu/hr) (ton/hr) 

Boitor •,,,.,,,, 7.2 0.8 

Fuel Type, 

% sulfur 

Wood 

Stack # 

Oil Fired Boilers 

Equipment 

Boiler # 1 

Furnace #3" 

Maximum 

Capacity 

(MMBtu/hr) 

8.4 

0.18 

Maximum 

Firing .Rate 

(•aFhr) 

60.0 

1.8 

1.8 

Fuel Type, 

% sulfur 

#2 fuel oil, 0.3% 

#2 fuel oil, 0.3% 

Stack # 

Wall Vent 

Furnace #4* 0.18 #2 fuel oil, 0.3% 7 

Furnace #5* 0.18 1.8 #2 fuel oil, 0.3% 8 

* Furnaces #3, #4 and #5 are considered insignificant activities based on Chapter 115 Appendix B 

Section B(3). The furnaces are noted on the license for inventory purposes only. 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

) 

) 

) 

2 

Diesel Units 

Departmental 

Findings of Fact and Order 

Air Emission License 

Equipment 

Diesel #1 

Maximum 

Capacity 

(kW) 

500 

Maximum 

firing Rate 

(•al/hr) 

36.4 

Fuel Type, 

% Sulfur 

Diesel, 0.3 % 

Date of 

Manufacture 

1996 

Stack# 

#3 

Process Equipment 

Equipment 

Kiln #1 

Kiln #2 

Kiln #3 

Kiln #4 

Kiln #5 

Kiln #6 

Production 

Rate 

60,000 BF 

60,000 BF 

Pollution Control 

Equipment 

none. 

30,000 BF 

none 

none 

30,000 BF none 

30,000 BF none 

30,000 BF none 

C. Application Classification 

The application for Northeastern does not include the licensing of increased 

emissions or the installation of new or modified equipment. Therefore, the 

license is considered to be a renewal of current licensed emission units only. This 

source is determined to be a minor source and has been processed as such. 

II. BEST PRACTICAL TREATMENT (BPT) 

A. Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Definitions Regulation, 06-096 CMR 100 (last amended 

December 1, 2005). Separate control requirement categories exist for new and 

existing equipment as well as for those sources located in designated nonattainment areas. 

BPT for existing emissions equipment means that method which controls or 

reduces emissions to the lowest possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emission 

from the source being considered; and 

the economic feasibility for the type of establishment involved. 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

) 

) 

) 

3 

Departmental 

Findings of Fact and Order 

Air Emission License 

B. #2 Fuel Oil Fired Boiler #1 

Northeastern was previously licensed to operate two equal sized and 

manufactured #2 fuel oil fired boilers, designated Boilers #1 and #2, as a 

supplemental heat supply and for kiln drying. Boiler #2 has been rendered in 

operable and scavenged for parts and therefore will be removed from 

Northeastem's air emission license. 

Boiler #1 has a maximum design heat input capacity of 8.4 MMBtu/hr, exhausts 

to Stack #1 and is licensed to fire #2 fuel oil with a sulfur content of no greater 

than a monthly.average of 0.3% sulfur by weight. 

Boiler #1 is below the 10 MMBtu/hr deminimus threshold and is therefore not 

subject to EPA New Source Performance Standards (NSPS) 40 CFR Part 60, 

Subpart Dc, for boilers with a maximum design heat input capacity of 10 

MMBtu/hr or greater and manufactured after June 9, 1989. 

A summary of the BPT analysis for Boilers #1 (8.4 MMBtu/hr) is as follows: 

1. Fuel Burning Equipment Particulate Emission Standard, 06-096 CMR 103, 

(last amended November 3, 1990) regulates PM emission limits. However, 

the PM emission limit of 0.12 lb/MMBtu when firing #2 fuel oil is more 

stringent and shall be considered BPT. PM•0 emission limits are derived from 

PM limits. 

2. Low Sulfur Fuel, 06-096 CMR 106 (last amended July 4, 1999) regulates fuel 

sulfur content. However the use of #2 fuel oil with a sulfur content of no 

greater than a monthly average 0.3% sulfur by weight is more stringent and 

shall be considered BPT. 

3. SO2, NOx, CO and VOC emission limits are based upon AP-42 data dated 

9/98. 

4. Visible emissions from the boilers are subject to Visible Emissions 

Regulation, 06-096 CMR 101 (last amended May 18, 2003). Visible 

emissions from the Boiler #1 stack shall not exceed 20% opacity on a 

six-minute block average except, for no more than 2 six-minute block 

averages in a 3-hour period. 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

) 

) 

) 

4 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Wood Fired Boiler #6 

Northeastern operates a wood fired boiler, designated Boiler #6, as the principle 

heat source for the drying kilns and sawmill. Boiler #6 was manufactured in 

2006, has a maximum design heat input capacity of 7.2 MMBtu/hr and exhausts 

through a new 50 foot AGL stack, designated Stack #6. The majority of wood 

burned is from production rejects consisting of sawdust, bark, trim, sort-yard 

debris, chip fines, shavings, etc. Although some post kiln dried wood 

waste will likely be burned, the vast majority will be from pre kiln dried 

production rejects from the sawmill operation. 

Boiler #6 is below the 10 MMBtu/hr deminimus threshold and is therefore not 

subject to EPA New Source Performance Standards (NSPS) 40 CFR .Part 60, 

Subpart Dc, for boilers with a maximum design heat input capacity of 10 

MMBtu/hr or greater and manufactured after June 9, 1989. 

A summary of the BPT analysis for Boiler #6 (7.2 MMBtu/hr) is as follows: 

1. PM, PM•0, SO2, NOx, •lL'• •nd VOC emission •ts axe based upon AP-42 

data dated 9/03. 

2. Visible emissionsfrom the boiler are subject to 06-096 CMR 101. Visible 

emissions from Stack #6 shall not exceed 20% opacity on a 6-minute average, 

except for no more than two 6-minute periods in a 3-hour period. 

D. #2 Fuel Oil Fired Boiler #1 and Wood Fired Boiler #6 Fuel Limits 

Rather than imposing a licensed fuel restriction, Northeastern has requested to be 

restricted to a facility wide boiler heat input restriction in order to allow the 

facility operational flexibility to work out issues with the wood fired boiler and 

still satisfy their steam supply needs. 

Northeastern has requested that the facility be restricted to a facility wide boiler 

heat input restriction of 93,000 MMBtu/yr on a twelve-month rolling total basis. 

This is the equivalent of approximately 215,000 gallons per year (gal/yr) of #2 

fuel oil plus 7,008 ton/yr of 50% moisture wood or equivalent, which 

Northeastern had estimated would satisfy their fuel needs. 

Northeastern has not requested a change in the facility's #2 fuel oil sulfur content 

restriction, therefore, Northeastern shall continue to be subject to the previously 

licensed restriction for #2 fuel oil fired in Boilers #1 and #2 of no greater than a 

monthly average of 0.3% sulfur by weight. 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Compliance with the facility wide heat input restriction for Boilers #1 and #6 

shall be documented via a fuel use record that will be maintained on a monthly as 

well as a twelve-month rolling total basis. The fuel use record shall include the 

amount of fuel fired, either wood or #2 fuel oil, certification of the sulfur content 

of the #2 fuel oil and calculations converting the fuel usage into MMBtu heat 

input. Heat input shall be calculated using the following formulas: 

1. For #2 fuel use: Heat input equals (#2 fuel usage (in gallons) x 140,000 Btu 

per gallon of #2 fuel) 

2. For wood fuel use: Heat input equals (wood fuel usage (in pounds) x 4500 Btu 

per pound of wood) 

E. Northeastem also makes use of several small #2 fuel oil/waste oil fumaces for 

space heating in some of the facility's production areas. The heaters are all below 

the 1.0 MMBtu/hr deminimus threshold of applicability for Chapter 115 of the 

Department's regulations and are mentioned in this permit for inventory purposes 

only. 

F. Diesel Unit #1 

Northeastern was previously licensed to operate two diesel generator units, 

designated Diesel Units #1 and #2. Diesel Unit #2 has been removed from the 

facility and therefore will be removed from Northeastern's air emission license. 

Diesel Unit #1 is a Mitsubishi manufactured engine with a design output capacity 

of 500 kW. 

Northeastern has requested that the diesel generator unit be licensed for a 

maximum of 500 hours of operation based on a twelve-month rolling total. To 

demonstrate compliance with the hours of operation restriction, Northeastern shall 

be required to install, operate and maintain an hour meter on Diesel Unit #1 and 

maintain a record of use of the unit which shall include the date of operation of 

the unit, the hours operated and the circumstances which required the operation of 

the unit. The diesel unit use record shall be maintained on a monthly and 

twelve-mon•th rolling total basis. 

A summary of the BACT analysis for Diesel Units #1 is as follows: 

1. 06-096 CMR 103, (last amended November 3, 1990) regulates PM emission 

limits. HoWever, the PM emission limit of 0.12 lb/MMBtu is more stringent 

and shall be considered BPT. PMl0 emission limits are derived from PM 

limits. 

2. 06-096 CMR 106 regulates fuel sulfur content. However the use of#2 fuel oil 

with a sulfur content of no greater than a monthly average of 0.3% sulfur by 

weight is more stringent and shall be considered BPT. 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

) 

) 

) 

6 

Departmental 

Findings of Fact and Order 

Air Emission License 

SOz, NOx, CO and VOC emission limits are based upon AP-42 data dated 

10/96. 

Visible emissions from Diesel Unit #1 is subject to 06-096 CMR 101. Visible 

emissions from the diesel exhaust stack shall not exceed 20% opacity on a 

six-minute block average, except for no more than 2 six-minute block 

averages in a 3-hour period. 

G. Process Equipment 

Northeastern Log Homes operates six kilns for drying. The six kilns have the 

capacity to hold a total of 240,000 BF of wood. Northeastern Log Homes 

currently only dries Eastern White Pine in their kilns but other wood species may 

be dried in their kilns. The drying of softwood significantly contributes to the 

facility's VOC emissions. Northeastern Log Homes shall not exceed a limit of 

37,000,000 board feet of wood processed per year based on a twelve-month 

rolling total. 

VOC emissions rates are based on a factor of 2.26 lb/1000 BF of Eastern White 

Pine. VOC emissions from the kiln operation are calculated to be 42.0 tons of 

VOC per year. To demonstrate compliance with the production limit of 

37,000,000 board feet, Northeastern shall maintain a record of the quantity of 

wood dried in the kilns in board feet. The record shall be maintained on a 

monthly and a twelve-month rolling total basis. 

H. Quarterly Reporting 

Northeastern shall be required to provide a quarterly report demonstrating fuel 

usage, fuel sulfur content and kiln production. The quarterly reports shall be due 

on the last of January, April, July and October of each year. A copy of the 

quarterly report shall be submitted to the Department's Augusta, Maine and 

Bangor, Maine offices. 

I. Annual Emission Restrictions 

Emissions calculations for Boilers #1 and #6 are based on an annual heat input 

restriction of 93,000 MMBtu/yr for the worst case scenario of either the oil 

fired boiler or the wood fired boiler. 

Emissions calculations for Diesel Unit #1 is based on annual hours of 

operation limit of 500 hours and the use of #2 fuel oil With a maximum sulfur 

content of no greater than a monthly average of 0.3% by weight. 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

) 

) 

) 

7 

Departmental 

Findings of Fact and Order 

Air Emission License 

Total Allowable Annual Emission for the Facility 

(used to calculate the annual license fee) 

Pollutant 

Boilers #1 and #6 

PM 21.4 

PM10 21.4 

Tons/Year 

Drying Kilns Diesel Unit #1 

0.2 

20.0 

0.2 

SO2 14.2 0.4 

NOx 11.4 4.1 

CO : 

VOC 0.7 41.8 

1.1 

0.1 

Total 

21.6 

21.6 

14.6 

15.5 

21.1 

42.6 

III.AMBIENT AIR QUALITY ANALYSIS 

According to Major and Minor Source Air Emission License Regulations, 06-096 CMR 

115 (last amended December 1, 2005), the level of air quality analyses required for a 

minor source shall be determined on a case-by case basis. Based on the information 

available in the file, and the similarity to existing sources, Maine Ambient Air Quality 

Standards (MAAQS) will not be violated by this source. Based on the total facility 

emissions, Northeastem is below the emissions level required for modeling and 

monitoring. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission 

following conditions: 

License A,642-71-I-R subject to the 

Severability. The invalidity or unenforceability of any provision, or part thereof, of this 

License shall not affect the remainder of the provision or any other provisions. This 

License shall be construed and enforced in all respects as if such invalid or unenforceable 

provision or part thereof had been omitted. 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(Title 38 MRSA §347-C). 

(2) The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, 'unless specifically provided for in 

06-096 CMR 115. [06-096 CMR 115] 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [06-096 CMR 115] 

(4) The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. [06-096 CMR 115] 

(5) The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. [06-096 CMR 115] 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. [06•096 CMR 115] 

(8) The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [06-096 CMR 115] 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(9) The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [06-096 CMR 115] 

(10) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [06-096 CMR 115] 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

(i) perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

a. within sixty (60) calendar days of receipt of.a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

b. pursuant to any other requirement of this license to perform stack testing. 

(ii) install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

(iii)submit a written report to the Department within thirty (30) days from date of 

test completion. 

[06-096 CMR 115] 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

(i) within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

) 

) 

) 

10 

Departmental 

Findings of Fact and Order 

Air Emission License 

(ii) the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

(iii)the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. [06-096 CMR 115] 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [06-096 CMR 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[06-096 CMR 115] 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. [06-096 CMR 115] 

SPECIFIC CONDITIONS 

(16) #2 Fuel Oil Fired Boiler #1 

A. Northeastern shall be li.mited to firing #2 fuel oil with a sulfur content of no 

greater than a monthly average of 0.3% sulfur by weight in Boiler #1. 

[06-096 CMR 115, BPT] 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

) 

) 

) 

11 

Departmental 

Findings of Fact and Order 

Air Emission License 

B. Emissions shall not exceed the following: 

Equipment 

lb/MMBtu 

Boiler #1 lb/hr 

PM PMlo 

0.12 

1.0 1.0 2.6 

SO2 

06:096 CMR 115, BPT] 

NOx CO 

1.2 0.3 

VOC 

0.02 

Co Visible emissions from Stack #1 shall not exceed 20% opacity on a six-minute 

block average except, for no more than 2 six-minute block averages in a 

3-hour period. [06-096 CMR 101] 

(17) Wood Fired Boiler #6 

A. Emissions shall not exceed the following: 

Equipment PM PM•0 SO2 NOx VOC 

lb/MMBtu 0.56 

Boiler #6 lb/hr 4.0 4.0 0.2 1.6 •,•" 0.1 

[06-096 CMR 115, BPT] 

Bo Visible emissions from Stack #6 shall not exceed 20% opacity on a six-minute 

average, except for no more than 2 six-minute periods in a 3-hour period. [06- 

096 CMR 101] 

(18) Fuel Limit for Boilers #1 and #6 

A° Northeastern shall be restricted to a facility wide boiler heat input restriction 

of 93,000 MMBtu/yr on a twelve-month rolling total basis. 

[06-096 CMR 115, BPT] 

B. Northeastern shall maintain a fuel use log which shall include the amount of 

fuel fired, either wood or #2 fuel oil, certification of the sulfur content of the 

#2 fuel oil and calculations converting the fuel usage into MMBtu heat input. 

Heat input shall be calculated using the-following formulas: 

1. For #2 fuel use: Heat input (#2 fuel usage (in gallons) x 140,000 Btu 

per gallon of #2 fuel) 

2. For wood fuel use: Heat input (wood fuel usage (in pounds) x 4500 Btu 

per pound of wood at 50% moisture or equivalent) 

[06-096 CMR 15, BPT] 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71,I-R 

) 

) 

) 

12 

Departmental 

Findings of Fact and Order 

Air Emission License 

(19) Diesel Unit #1 

Ao Northeastern shall be permitted to operateDiesel Unit #1 a total of 500 hours 

per year based on a twelve-month rolling total. 

[06-096 CMR 115, BPT] 

Bo Northeastern shall be limited to firing #2 fuel oil with a sulfur' content no 

greater than a monthly average of 0.3% sulfur by weight in the diesel unit. 

[06-096 CMR 115, BPT] 

C. Northeastern shall install, operate and maintain an hour meter on Diesel 

Unit #1. [06-096 CMR 115, BPT] 

Do Northeastern shall maintain a record of use of Diesel Unit #1 which shall 

include the date of. operation of the unit, the hours operated and the 

circumstances which required the operation of the unit. The diesel unit use 

record shall be maintained on a monthly and twelve-month rolling total basis. 

[06-096 CMR 115, BPT] 

E. Emissions shall not exceed the following: 

Equipment PM PM•0 SO2 NOx CO VOC 

lb/MMBtu 0.12 

Diesel Unit #1 lb/hr 0.6 0.6 1.0 16.3 4.3 1.0 

[06-096 CMR 115, BPT] 

Fo Visible emissions from the diesel exhaust stack shall not exceed 20% opacity 

on a six-minute block average, except for no more than 2 six-minute block 

averages in a 3-hour period. [06-096 CMR 101 

(20) Drying Kilns 

Wood drying in the drying kilns shall be limited to 37 MMBF of wood per year 

based on a twelve-month rolling total. Northeastern shall maintain a log for the 

drying kilns, including amounts of each species processed on a monthly basis, in 

addition to a twelve-month rolling total. [06-096 CMR 115, BPT] 

(21) Visible emissions from potential sources of fugitive particulate matter emissions, 

including material stockpiles and unpaved roadways, shall not exceed an opacity 

of 20%, except for no more than 5-minutes in any 1-hour period. Compliance 

shall be determined by an aggregate of the individual 15-second opacity 

observations which exceed 20% in any 1-hour. [06-096 CMR 101] 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

) 

) 

) 

13 

Departmental 

Findings of Fact and Order 

Air Emission License 

(22) Visible emissions from any general process source, including wood handling and 

storage, shall not exceed an opacity of 20% on a 6 minute block average basis, 

except for no more than six minute block average in a 1 hour period. 

[06-096 CMR 101] 

(23) Quarterly Reporting 

(24) 

A. Northeastern Log Homes shall be required to provide to the Department, a 

quarterly report demonstrating fuel usage, fuel sulfur content and kiln 

production. [06-096 CMR 115] 

B. The quarterly reports shall be due on the last of January, April, July and 

October of each year. A copy of the quarterly report shall be submitted to the 

Department's Augusta, Maine and Bangor, Maine offices. [06-096 CMR 115] 

Annual Emission Statement 

In accordance with Emission Statements, 06-096 CMR 137 (last amended July 6, 

2004), the licensee shall annually report to the Department by July 1, the 

information necessary to accurately update the State's emission inventory by 

means of: 

1) A computer program and accompanying instructions supplied by the 

Department; or 

2) A written emission statement containing the information required in 06-096 

CMR 137. 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 

[06-096 CMR 137] 
Northeastern Log Homes, Inc. 

Penobscot County 

Kenduskeag, Maine 

A-642-71-I-R 

) 

) 

) 

14 

Departmental 

Findings of Fact and Order 

Air Emission License 

(25) Northeastem Log Homes shall notify the Department within 48 hours and submit 

a report to the Department on a quarterly basis if a malfunction or breakdown in 

any component causes a violation of any emission standard (Title 38 MRSA 

§605-C). 

DONE AND DATED IN AUGUSTA, MAINE THIS 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

BY: 

DAY OF 2008. 

DAVID P. LITTELL, COMMISSIONER 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

The term of this Order shall be for five (5) years from the signature above. 

Date of initial receipt of application: Angnst 17• 2007 

Date of application acceptance: August 27• 2007 

Date filed with the Board of Environmental Protection: 

This Order prepared by, Peter G. Carleton, Bureau of Air Quality 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license renewal application, staff investigation reports 

and other documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 

M.R.S.A., Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Lovell Lumber Company, Inc. (Lovell) of Lovell, Maine has applied to renew 

their Air Emission License permitting the operation of emission sources 

associated with their Lovell, Maine sawmill and Planer-mill. 

B. Emission Equipment 

Lovell is authorized to operate the following equipment: 

Fuel Burning Equipment 

Equipment 

Diesel #1 

Diesel #2 

Diesel #3 

Boiler #5 

Maximum 

Capacity 

•'MMBtu/hr) 

5.5 

1.2 

5.5 

Maximum 

Firin• Rate 

40.4 gal/hr 

9.0 gal/hr 

40.4 gal/hr 

8.6 1920 lb/hr 

5.2 37.5 gal/hr 

Fuel Type, 

% sulfur 

Diesel, 0.05% 

Diesel, 0.05% 

Date of 

Manufacture 

1998 

1993 

Diesel, 0.05% 

Diesel, 0.05% 

1993 

1982 

1984 

Stack # 

#1 

#1 

#1 

#4 

#5 

Process Equipment 

Equipment 

Kiln #1 

Production Rate 

4.5 MMBF/yr 

Pollution Control 

Equipment 

none 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Application Classification 

The application for Lovell Lumber does not include the licensing of increased 

emissions or the installation of new or modified equipment. Therefore, the 

license is considered to be a renewal of current licensed emission units only. 

II. BEST PRACTICAL TREATMENT (BPT) 

A. Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for existing emissions equipment means that method which controls or 

reduces emissions to the lowest possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emission from 

the source being considered; and 

the economic feasibility for the type of establishment involved. 

B. Facility Description 

Lovell is a sawmill and planer-mill facility that produces kiln-dried and surfaced 

eastern white pine lumber. Eastern white pine logs enter the facility and are 

measured and sent to a storage area. The logs are removed from the storage area 

in a first in/first out order and sent to the debarker where the bark is removed from 

the logs. The debarked logs are then sent to the sawmill and the remaining bark is 

stored and eventually sold as bark mulch. 

Lovell operates one double cut bandsaw which does the initial board cutting. The 

rough cut boards are sent through an edger and trimmer, then graded and sorted. 

Sawdust from the sawmill is collected with cyclones and stored in a silo to be 

used as fuel in the wood fired boiler. The boiler produces steam to heat the 

buildings and the drying kiln. Larger waste wood pieces from the sawmill are 

chipped and sold to the paper industry. 

The boards are dried for two weeks in the kiln or for 3-4 months if they are air 

dried in the lumber yard. Dried boards are sent to the planer-mill. Here the 

lumber is trimmed to exact length, smoothed, and any molding or joining cuts are 

done. 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Shavings from the planing process are blown to the bagger house, bagged and 

sold as animal :bedding. Sawdust and chipped ends from the planing process are 

fed to the wood fuel silo, for use as fuel in the wood fired boiler. From the 

planer-mill, the boards are sent to storage to await shipment. 

Lovell operates Boilers #4 and #5 as the principle heat source for the facility's 

drying kilns and sawmill and planer-mill buildings. Boiler #4 is a wood fired 

boiler and Boiler #5 fires diesel fuel. Lovell also operates three diesel generators 

(one primary and two back-ups) to produce power for their facility. Lovell is 

required to fire diesel fuel with a sulfur content of no greater than 0.05% sulfur by 

weight. 

C. Boilers #4 and #5 

Lovell operates Boilers #4 and #5 as the principle heat source for the facility's 

drying kilns and sawmill and planer-mill buildings. The design heat input 

capacity for Boilers #4 and #5 each is below the applicability threshold for EPA 

New Source Performance Standards (NSPS) 40 CFR, Subpart Dc, for boilers with 

a maximum design heat input capacity of 10 MMBtu/hr or greater and 

manufactured after June 9, 1989. 

1. Boiler #4 

Boiler #4 is a wood-fired low-pressure boiler, manufactured in 1982 with a 

maximum design heat input of 8.6 MMBtu/hr. Boiler #4 exhausts through 

Stack #4. 

Boiler #4 makes use of a cyclone to control particulate emissions exhausting 

from the wood-fired boiler. Lovell shall establish an inspection/maintenance 

program for the Boiler #4 cyclone which shall allow for periodic emptying of 

the cyclone drop container when the drop container is full. The 

inspection/maintenance program shall also allow for monthly visual 

inspections of the cyclone shell and drop point to inspect for any fractures or 

holes in the cyclone shell that would effect its operation and to determine .the 

necessity of emptying the drop container. Lovell shall record the dates and 

findings of monthly visual inspections as well as any necessary maintenance 

and drop container emptying in an inspection/maintenance log. 

Lovell is restricted to firing no greater than 7,570 tons of wood per year 

(ton/yr) of 50% moisture wood or equivalent, based on a twelve-month rolling 

total. Lovell shall maintain a fuel use record which demonstrates compliance 

with the facility's fuel consumption restriction for Boiler #4. The fuel use 

record shall be maintained on a monthly as well as a twelve-month rolling 

total basis. 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

A summary of the BPT analysis for boiler #4 (8.6 MMBtu/hr) is as follows: 

1. MEDEP Chapter 103 regulates PM emission standards for wood fired 

boilers. Based on MEDEP Chapter 103, the BPT emission factor for PM 

for Boiler #4 shall be 0.3 lb/MMBtu. PM10 emission limits are based on 

PM limits. 

2. Emissions from boiler #4 shall be vented through a cyclone before 

entering stack #4. 

3. SO2, NOx, CO and VOC emission limits are based upon AP-42 data dated 

7/01 for wet-wood fired boilers. 

4. Visible emissions from Stack #4 shall not exceed 30% on a 6-minute 

block average, except for no more than 2 six-minute block averages in a 

3-hour period. 

2. Boiler #5 

Boiler #5 is a Clever Brooks boile• .manufactured in 1984 with a maximum 

design heat input of 5.2 MMBtu/hr. Boiler #5 exhausts through Stack #5. 

As per Lovell's previous air emission license (A-676-71-C-R), Lovell is 

restricted to a facility wide diesel fuel oil limit of 155,000 gallons per year 

(gal/yr) based on a twelve-month rolling total. This restriction includes fuel 

fired in Boiler #5 and the facility's diesel engines. Lovell has not requested a 

change in this restriction and therefore shall continue to be subject to this 

restriction. Lovell shall maintain a fuel use record which demonstrates 

compliance with the facility's diesel fuel restri•ction. The fuel use record shall 

be maintained on a monthly as well as a twelve-month rolling total basis. 

A summary of the BPT analysis for boiler #5 (5.2 MMBtu/hr) is as follows: 

1. MEDEP Chapter 103 establishes PM emissions standards for oil fired 

boilers. Based on MEDEP Chapter 103, the BPT emission factor for PM 

for Boiler #5 shall be 0.12 Ib/MMBtu. PM10 emission limits are based on 

PM limits. 

2. BPT for diesel fuel oil is a sulfur content of 0.05% by weight. 

3. NOx emission limits are based on performance data from similar diesel 

fuel oil fired boilers of this size and age and manufacturer's data: 

BPT emission factor for NOx for diesel fuel oil is 0.3 lb/MMBtu. 

4. CO and VOC emission limits are based upon AP-42 data dated 9/98 and 

performance data from the boiler's manufacturer. 

5. Visible emissions from Stack #5 shall not exceed 20% opacity on a (6) 

six-minute block average except, for no more than 2 six-minute block 

averages in a 3-hour period. 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

D. Diesel Units #1, #2 and #3 

Diesel Units #1, #2 and #3 were manufactured in 1998, 1993 and 1993 and 

have maximum heat input capacities of 5.5 MMBtu/hr, 1.2 MMBtu/hr and 

5.5 MMBtu/hr respectively, firing diesel fuel with a sulfur content of no greater 

than 0.05% sulfur by weight. All three diesels exhaust to a common stack, 

designated Stack #1. 

As discussed above, Lovell is restricted to a facility wide diesel fuel restriction of 

155,000 gal/yr based on a twelve-month rolling total. The fuel use restriction 

includes fuel consumed in the diesel engines as well as Boiler #5. 

A summary of the BPT analysis for Diesel Units #1, #2 and #3 is the following: 

1. MEDEP Chapter 103 regulates PM emission standards from diesel units #1 

and #3, for diesels greater than 3 MMBtu/hr. PM10 emission limits are based 

on PM limits. 

2. BPT for diesel fuel oil is a sulfur content of 0.05% by weight. 

3. NOx, CO and VOC emission limits for diesel units #1 and #3 are based on 

AP-42 data dated 10/96 for diesel units larger than 600 hp; PM, NOx, CO and 

VOC emission limits for diesel unit #2 are based on AP-42 data dated 10/96 

for diesel units smaller than 600 hp. 

4. Visible emissions from Diesel units #1, #2 and #3 (Stack 1) fired individually 

shall not exceed 20% on a 6-minute block average. Opacity from diesel units 

#1, #2 and #3 fired in combination shall not exceed 30% opacity on a 

6-minute block average, except for no more than 2 six minute block averages 

in a 3-hour period. 

E. Drying Kilns 

Lovell currently operates one kiln, designated Kiln #1, for green lumber drying. 

Kiln #1 has a 4.5 MMBF/yr through-put rate. Lovell shall maintain a record of 

wood drying. The record shall include the quantity of wood dried in the kilns 

indicating species and drying dates. The record shall also include the quantity of 

any wood air-dried, indicating species and drying dates. The record shall be 

maintained on a monthly as well as a twelve-month rolling total. 

Lovell predominantly dries Eastern White Pine. Using the emission factor of 

2.26 pounds of VOC per 1000 board feet for white pine and the current annual 

drying production from the Lovell kilns of 4.5 MMBF per year, Lovell emits 

approximately 2.8 tons of VOC per year from the kiln drying process. 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

) 

) 

) 

6 

Departmental 

Findings of Fact and Order 

Air Emission License 

F. Cyclone 

Lovell makes use of cyclones to control particulate emissions from sawing and 

planning processes. Lovell shall establish an inspection/maintenance program for 

the process cyclones which shall allow for periodic emptying of the cyclone drop 

containers when the drop containers are full and for monthly visual inspections of 

the cyclone shells and drop points to inspect for any fractures or holes in the 

cyclone shell that would effect its operation and to determine the necessity of 

emptying the drop containers. Lovell shall record the dates and findings of 

monthly visual inspections as well as any necessary maintenance and drop 

container emptying in an inspection/maintenance log. 

Visible emissions from the cyclone shall not exceed opacity of 10% on a 6-minute 

block average basis. 

G. Annual Emission Restrictions 

Lovell shall be restricted to the following annual emissions, based on a 12 month 

rolling total: 

• Lovell is restricted facility wide to firing no greater than" 155,000 gal/yr of 

diesel fuel oil with a maximum sulfur content not to exceed 0.05% by weight. 

• Lovell is restricted to firing no greater than 7,570 ton/yr of 50% moisture 

wood or equivalent in Boiler #4 based on a twelve-month rolling total. 

• Lovell is restricted to drying no greater than 4.5 MMBF/yr of lumber based on 

a twelve:month rolling total. 

Total Allowable Annual Emission for the Facility 

(used to calculate the annual license fee) 

Pollutant 

Boilers 

SO2 

10.2 

Tons/Year 

Diesels Kiln 

PM 1.3 

PM10 10.2 1.3 

015 

NOx 

0.9 

7.5 

20.5 

1.3 

CO 

VOC 

34.0 

Total 

11.5 

11.5 

1.4 

41.5 

29..5 

7.5 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

) 

) 

) 

7 

Departmental 

Findings of Fact and Order 

Air Emission License 

III.AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a minor source shall be determined on a case-by case basis. Based on the 

information available in the file, and the similarity to existing sources, Maine Ambient 

Air Quality Standards (MAAQS) will not be violated by this source. Based on the total 

facility emissions, Lovell is below the emissions level required for modeling and 

monitoring. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from 'this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission 

following conditions: 

License A-676-71-D-R subject to the 

Severability. The invalidity or unenforceability of any provision, or part thereof, of this 

License shall not affect the remainder of the provision or any other provisions. This 

License shall be construed and enforced in all respects as if such invalid or unenforceable 

provision or part thereof had been omitted. 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(Title 38 MRSA §347-C). 

(2) The licensee Shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is- discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension ig justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. 

(4) The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. 

(5) The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. 

(8) The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request, 

(9) The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. 

(10) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions .of the air emission 

license. 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

Departmental. 

Findings of Fact and Order 

Air Emission License 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

(i) perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

a. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; 

or 

b. pursuant to any other requirement of this license to perform stack testing. 

(ii) install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

(iii)submit a written report to the Department within thirty (30) days from date of 

test completion. 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in. excess of 

the applicable standards, then: 

(i) within thirty (30) days following receipt of Such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 

(ii) the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

) 

) 

) 

10 

Departmental 

Findings of Fact and Order 

Air Emission License 

(iii)the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. 

SPECIFIC CONDITIONS 

(16) Boiler #4 

Lovell shall be limited to firing no greater than 7,570 ton/yr of'50% moisture 

wood or equivalent based on a twelve month rolling total in Boiler #4. Lovell 

shall maintain a fuel use record which demonstrates compliance with the 

facility's fuel consumption restriction for Boiler #4. The fuel use record shall 

be maintained on a monthly as well as a twelve-month rolling total basis. 

[MEDEP Chapter 115, BPT] 

Bo Lovell shall establish an inspection/maintenance program for the Boiler #4 

cyclone which shall allow for periodic emptying of the cyclone drop container 

when the drop container is full and for monthly visual inspections of the 

cyclone shell and drop point to inspect for any fractures or holes in the 

cyclone shell that would effect its operation and to determine the necessity of 

emptying the drop container. [MEDEP Chapter 115, BPT] 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

) 

) 

) 

11 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Emissions shall not exceed the following: 

Equipment 

lb/MMBtu 

Boiler #4 lb/hr 

[ME•)EP Chapter 115, BPT] 

PM PM10 SO2 NOx CO VOC 

.0.3 

2.6 2.6 0.2 1.9 5•2 0.3 

D. Visible emissions from Stack #4 shall not exceed 30% on a 6-minute block 

average, except for no more than 2 six-minute block averages in a 3-hour 

period. [MEDEP Chapter 101] 

(17) Lovell shall be restricted to a facility wide diesel fuel oil limit of 155,000 gallons 

per year (gal/yr) based on a twelve-month rolling total with a sulfur content of no 

greater than 0.05% sulfur by weight. Lovell shall maintain a fuel use record 

which demonstrates compliance with the facility's diesel fuel restriction. The fuel 

use record shall be maintained on a monthly as well as a twelve-month rolling 

total basis. [MEDEP Chapter 115, BPT] 

(18) Boiler #5 

A. Emissions from Boiler #5 shall not exceed the following: 

Equipment PM PMlo SO2 NOx CO VOC 

lb/MMBtu 0.12 

Boiler #5 lb/hr 0.6 0.6 0.3 1.6 0.2 0.01 

MEDEP Chapter 115, BPT] 

B. Visible emissions from stack #5 shall not exceed 20% opacity on a 6-minute 

block .average except, for no more than 2 six-minute block averages in a 

3-hour period. [MEDEP Chapter 101] 

(17) Diesel Units #1, #2 and #3 

A. Emissions from Diesels #1, #2 and #3 shall not exceed the following: 

Equipment ' 

lb/MMBtu 

Diesel #1 lb/hr 

Diesel #2 lb/hr 

lb/MMBtu 

Diesel #3 lb/hr 

MEDEP Chapter 115, BPT] 

PM PM10 SO2 

0.12 

0.65 0.65 0.3 

0.4 0.4 0.06 

0.12 

0.65 0.65 0.3 

NOx CO 

17.4 4.6 

5.4 1.2 

17.4 4.6 

VOC 

0.5 

0.4 

0.5 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

) 

) 

) 

12 

Departmental 

Findings of Fact and Order 

Air Emission License 

Bo Visible emissions from Diesel units #1, #2 and #3 (Stack 1) fired individually 

shall not exceed 20% on a 6-minute block average. Opacity from diesel units 

#1, #2 and #3 fired in combination shall not exceed 30% opacity on a 

6-minute block average, except for no more than 2 six minute block averages 

in a 3-hour period. IMEDEP Chapter 101 

(18) Drying Kilns 

A. Lovell shall be restricted to drying no greater than 4.5 MMBF/yr of lumber 

based on a twelve-month rolling total. [MEDEP Chapter 115, BPT] 

Bo Lovell shall maintain a record of wood drying. The record shall include the 

quantity of wood dried, indicating species and drying dates. The record shall 

be maintained on a monthly as well as a twelve-month rolling total. 

[MEDEP Chapter 115, BPT] 

(19) Cyclones 

A. Visible emissions from any process cyclone shall not exceed opacity of 10% 

on a 6-minute block average basis. [MEDEP Chapter 101 

Lovell shall establish an inspection/maintenance program for the process 

cyclones which shall allow for periodic emptying of the cyclone drop 

containers when the drop containers are full and for monthly visual 

inspections of the cyclone shells and drop points to inspect for any fractures or 

holes in the cyclone shell that would effect its operation and to determine the 

necessity of emptying the drop containers. Lovell shall record the dates and 

findings of monthly visual inspections as well as any necessary maintenance 

and drop container emptying in an inspection/maintenance log. 

[MEDEP Chapter 115, BPT] 

(20) Visible emissions from any general process source shall not exceed opacity of 

10% on a 6-minute block average basis, except for no more than 1 six-minute 

block average in a 1-hour period. [MEDEP Chapter 101 

(21) Visible emissions .from potential sources of fugitive particulate matter emissions, 

including material stockpiles and unpaved roadways, shall not exceed an opacity 

of 20 percent, except for no more than 5-minntes in any 1-hour period. 

Compliance shall be determined by an aggregate of the individual 15-second 

opacity observations which exceed 20 percent in any 1-hour. 

[MEDEP Chapter 101 
Loveil Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A-676-71-D-R 

) 

) 

) 

13 

Departmental 

Findings of Fact and Order 

Air Emission License 

(22) Annual Emission Statement 

In accordance with MEDEP Chapter 137, the licensee shall annually report to the 

Department by September 1, the information necessary to accurately update the 

State's emission inventory by means of: 

1) A computer program and accompanying instructions supplied by the 

Department; 

or 

2) A written emission statement containing the information required in MEDEP 

Chapter 137. 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207)287-2437 

(23) Lovell shall notify the Department within 48 hours and submit a report to the 

Department on a quarterly basis if a malfunction or breakdown in any component 

causes a violation of any emission standard (38 MRSA §605-C). 
Lovell Lumber Company, Inc. 

Oxford County 

Lovell, Maine 

A'-676.71-D-R 

) 

) 

) 

14' 

Departmental 

Findings of Fact and Order 

Air Emission License 

(24) Lovell shall pay the annual air emission license fee within 30 days of 

December31 of each year. Pursuant to 38 MRSA 353-A, failure to pay this 

annual fee in the stated timeframe is sufficient grounds for the revocation of the 

license under 38 MRSA 341-D, Subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 2007. 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

BY: 

DAVID P. LITTELL, COMMISSIONER 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

The term of this Order shall be for five (5) years from the signature above. 

Date of initial receipt of application: November 27• 2006 

Date of application acceptance: December 5• 2006 

Date filed with the Board of Environmental Protection: 

This Order prepared by, Peter G. Carleton, Bureau of Air Quality 
Hancock Lumber Co:, Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

After review of the air emissions license application, staff investigation reports and other 

documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 M.R.S.A., 

Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Hancock Lumber Co., Inc. (Hancock) located in Pittsfield, Maine has applied for 

an Air Emission License permitting the operation of emission sources associated 

with their lumber mill. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Fuel Burning Equipment 

Equipment 

•r #I 

:•'l•aximum Maximum 

Capacity Firing Rate 

(MMBtu/hr) (ton/hr) 

12.6 1.4 

Fuel Type Stack # 

"•awdust and trim ends 1 

Process Equipment 

Equipment Production Rate 

Drying Kilns (6) 29 MMBF/year 

Pollution Control 

Equipment 

none 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

C. Application Classification 

Hancock is classified as an existing source that is applying for its first air 

emission license, after the fact. The Department has determined the facility is a 

minor source and the application has been processed through Chapter 115 of the 

Department's regulations. 

II. BEST PRACTICAL TREATMENT (BPT) 

Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for new sources and modifications requires a demonstration that emissions 

are receiving Best Available Control Technology (BACT), as defined in Chapter 

100 of the Department's regulations. BACT is a top-down approach to selecting 

air emission controls considering economic, environmental and energy impacts. 

B. Boiler #1 

Boiler #1 was manufactured by Industrial Boiler Inc. in 1985. It is currently 

being modified to provide for better control over the boiler and to make more 

steam with the same or slightly more fuel. This modification includes installing 

new grates, fans, fly ash collector, feed water tank, steam header, combustion air 

preheater, and stack. 

After these upgrades, the maximum heat input for Boiler #1 is expected to be 

12.6 MMBtu/hr firing wood (sawdust and trim ends). Hancock will use fly ash 

reinjection for control of particulate matter from Boiler #1. 

Boiler #1 was modified after 1989 and is therefore subject to the New Source 

Performance Standards (NSPS) Subpart Dc for steam generating units greater 

than 10 MMBtu/hr manufactured after June 9, 1989. 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, MaineA-932-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

A summary of the BACT analysis for Boiler #1 is the following: 

1. Hancock shall fire only wood (sawdust and trim ends) in Boiler #1. 

2. Hancock shall use the following formula, when necessary, to convert fuel use 

records to 50% moisture: 

Tons Wood at 50% (Tons Wood at M%) x [(100-M)/50] 

where M the moisture content of the actual wood fired 

3. Hancock shall continuously operate the fly ash reinjection system on 

Boiler #1 when Boiler #1 is in operation. 

4. Chapter 103 regulates PM emission limits. However in this case a BACT 

analysis for PM determined a more stringent limit of 0.33 lb/MMBtu was 

appropriate and shall be used The PM10 limits are derived from the PM limits. 

5. SO2, NOx, CO, and VOC emission limits are based upon AP-42 data dated 

9/03. 

6. Visible emissions from Boiler #1 shall not exceed 30% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. 

C. Degreaser Unit 

Hancock operates a degreaser unit with a design capacity of 5 gallons which uses 

diesel fuel as a solvent. Records shall be kept of the solvent added and removed. 

D. Kilns 

Hancock proposes to operate a total of six kilns for drying lumber. Heat for the 

kilns is provided by Boiler #1. The Department is not aware of any commercially 

available equipment for the control of VOCs from tlrying kilns. Therefore, BACT 

for the kilns is determined to be a yearly throughput limit of 29.0 million board 

feet based on a 12 month rolling total. 

Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed an opacity of 20 percent, except for no more than five 

(5) minutes in any 1-hour period. Compliance shall be. determined by an 

aggregate of the individual fifteen (15)-second opacity observations which exceed 

20 percent in any one (1) hour. 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 4 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

Annual Emissions 

Hancock shall be restricted to the following annual emissions, based on a 12 

month rolling total: 

Total Licensed Annual Emission for the Facility 

Tons/year 

(used to calculate the annual license fee) 

PM 

Boiler #1 18.2 

Kilns 

Total TPY 18.2 

PM•0 

18.2 

18.2 

S02 

1.4 

1.4 

NOx 

12.1 

12.1 

CO 

33.1 

33.1 

VOC 

0.9 

32.8 

33.7 

III.AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a minor new source shall be determined on a case-by case basis. 

Based on the information available in the file, and the similarity to existing sources, 

Maine Ambient Air Quality Standards (MAAQS) will not be violated by this source. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-932-71-A-N subject to the 

following conditions. 

Severabilit¥. The invalidity or unenforceability of any provision, or part thereof, of this 

License shall not affect the remainder of the provision or any other provisions. This 

License shall be construed and enforced in all respects as if such invalid or unenforceable 

provision or part thereof had been omitted. 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 

(2) 

(3) 

(4) 

(5) 

(6) 

(7) 

(8) 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(Title 38 MRSA §347-C). 

(9) 

The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [MEDEP Chapter 115] 

Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [MEDEP Chapter 115] 

The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the pr6gram to the Department upon 

request. [MEDEP Chapter 115] 

The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. [MEDEP Chapter 115] 

The license does not convey any property rights of any sort, or any exclusive 

privilege. [MEDEP Chapter 115] 

The licensee shall maintain and operate all emission units and air pollution 

,systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. [MEDEP Chapter 115] 

The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [MEDEP Chapter 115] 

The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated .noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [MEDEP Chapter 115] 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(10) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuant to any other requirement of this license to perform stack testing. 

B. install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test completion. 

[MEDEP Chapter 115] 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

A. within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 

B. the days of violation shall be presumed to include the da•e of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

C. the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

[MEDEP Chapter 115] 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 7 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [MEDEP Chapter 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 115] 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to detertnine the licensee's compliance status. [MEDEP Chapter 115] 

SPECIFIC CONDITIONS 

(16) Boiler #1 

A. Hancock shall fire only wood (sawdust 

[MEDEP Chapter 115, BACT] 

B. Emissions shall not exceed the following: 

and trim ends) in Boiler #1. 

Emission Unit Pollutant lb/MMBtu 

Boiler #1 PM 

Origin and Authority 

0.33 MEDEP Chapter 115, BACT 

C. Emissions shall not exceed the following [MEDEP Chapter 115, BACT]: 

Emission PM 

Unit (lb/hr) 

PMlo 

(lb/hr) 

SO2 NOx 

(lb/hr) 0b/hr) 

4.16 4.16 0.32 2.77 

CO VOC 

(lb/hr) (lb/hr) 

7.56 0.21 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 8 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

D. Hancock shall continuously operate fly ash reinjection on Boiler #1 whenever 

Boiler #1 is in operation. [MEDEP Chapter 115, BACT] 

E. Visible emissions from Boiler #1 shall not exceed 30% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. [MEDEP Chapter 101 

(17) New Source Performance Standards for De Boilers 

Boilerl #1 is subject to Federal New Source Performance Standards, Subpart Dc. 

Hancock shall comply with all requirements of 40 CFR Part 60, Subpart Dc 

including, but not limited to, the following: 

A. Hancock shall submit notification to EPA and the Department of the date of 

construction/reconstruction, anticipated start-up, and actual start-up. This 

notification shall include the design heat input capacity of the boiler and the 

type of fuel to be combusted. 

B. Hancock shall record and maintain records of the amounts of fuel combusted 

on a monthly basis. 

C. The following address for EPA shall be used for any reports or notifications 

required to be copied to them: 

Compliance Clerk 

USEPA Region 

1 Congress Street 

Suite 1100 

Boston, MA 02114-2023 

(18) Parts Washer 

Parts washers at Hancock are subject to MEDEP Chapter 130. 

A. Hancock shall keep records of the amount of solvent added to each parts 

washer. [MEDEP Chapter 115, BPT] 

B. The following are exempt from the requirements of Chapter 130 [MEDEP 

Chapter 130]: 

1. Solvent cleaners using less than two liters (68 oz) of cleaning solvent with 

a vapor pressure of 1.00 mmHg, or less, at 20 C (68 F); 

2. Wipe cleaning; and, 

3. Cold cleaning machines using solvents containing less than or equal to 5% 

VOC by weight. 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 9 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

C. The following standards apply to remote reservoir cold cleaning machines that 

are applicable sources under Chapter 130. 

1. Hancock shall attach a permanent conspicuous label to each unit 

summarizing the following operational standards [MEDEP Chapter 130]: 

(i) Waste solvent shall be collected and stored in closed containers. 

(ii) Cleaned parts shall be drained of solvent directly back to the cold 

cleaning machine by tipping or rotating the part for at least 15 

seconds or until dripping ceases, whichever is longer. 

(iii) Flushing of parts shall be performed with a solid solvent spray that is 

a solid fluid stream (not a fine, atomized or shower type spray) at a 

pressure that does not exceed 10 psig. Flushing shall be performed 

only within the freeboard area of the cold cleaning machine. 

(iv) The cold cleaning machine shall not be 6xposed to drafts, greater than 

40 meters per minute when the cover is open. 

(v) Sponges, fabric, wood, leather, paper products and other absorbent 

materials shall not be cleaned in the degreaser. 

(vi) When a pump-agitated solvent bath is used, the agitator shall be 

operated to produce no observable splashing of the solvent against 

the tank walls or the parts being cleaned. Air agitated solvent baths 

may not be used. 

(vii) Spills during solvent transfer shall be cleaned immediately. Sorbent 

material shall be immediately stored in covered containers. 

(viii) Work area fans shall not blow across the opening of the degreaser 

unit. 

(ix) The solvent level shall not exceed the fill line. 

2. The remote reservoir cold cleaning .machine shall be equipped with a 

perforated drain with a diameter of not more than six inches. [MEDEP 

Chapter 130, BPT] 

(19) Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed an opacity of 20 percent, except for no more than five 

(5) minutes in any 1-hour period. Compliance shall be determined by an 

aggregate of the individual fifteen (15)-second opacity observations which exceed 

20 percent in any one (1) hour. [MEDEP Chapter 101] 

(20) General Process Sources 

Visible emissions from any general process source shall not exceed an opacity of 

20% on a six (6) minute block average basis, except for no more than one (1) six 

(6) minute block average in a l-hour period. [MEDEP Chapter 101 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 10 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

(21) Kilns 

A. Hancock shall not exceed a yearly throughput of 29.0 million board feet per 

year based on a 12 month rolling total. [MEDEP Chapter 115, BACT] 

B. Hancock shall keep monthly records of board feet processed. 

[MEDEP Chapter 115, BACT] 

(22) Hancock shall notify the Department within 48 hours and submit a report to the 

Department on a quarterL, basis if a malfunction or breakdown in any component 

causes a violation of any emission standard (Title 38 MRSA •605). 

(23) Annual Emission Statement 

In accordance with MEDEP Chapter 137, the licensee shall annually report to the 

Department the information necessary to accurately update the State's emission 

inventory by means of: 

1) A computer program and accompanying instructions supplied by the 

Department; 

or 

2) A written emission statement containing the information required in 

MEDEP Chapter 137. 

Reports and questions should be directed to: 

Atm: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207)287-2437 

The emission statement must be submitted by July 1 or as otherwise 

specified in Chapter 137. 

(24) Air Toxics Emission Statement 

If Hancock exceeds the thresholds for HAPs listed in Appendix A of MEDEP 

Chapter 137 in an inventory year, in accordance with MEDEP Chapter 137 the 

licensee shall report, no later than July 1 every three years (2005, 2008, 2011, 

etc.) or as otherwise stated in Chapter 137, the infomaation necessary to 

accurately update the State's toxic air pollutants emission inventory by means of a 

written emission statement containing the information required in MEDEP 

Chapter 137. 
Hancock Lumber Co., Inc. 

Somerset County 

Pittsfield, Maine 

A-932-71-A-N 11 

Departmental 

Findings of Fact and Order 

Air Emission License 

After-the-Fact 

NOTE: Based on emission factors developed by the Eastern Research Group 

(ERG) in their memo "Development of Average Emission Factors and Baseline 

Emission Estimates for the Industrial, Commercial and Institutional Boilers and 

Process Heaters National Emission Standard for Hazardous Air Pollutants" dated 

October 2002, Hancock will most likely exceed the Chapter 137 thresholds of 

HAPs based on fuel burning alone should the facility exceed the firing of 1,403 

ton of wood in a calendar year. 

Reports and questions on the Air Toxics emissions inventory portion should be 

directed to: 

Attn: Toxics Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 

(25) Payment of Annual License Fee 

Hancock shall pay the annual air emission license fee within 30 days of 

January31 st of each year. Pursuant to 38 MRSA §353-A, failure to pay this 

annual fee in the stated timeframe is sufficient grounds for revocation of the 

license under 38 MRSA §341-D, subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

DAY OF 2006. 

BY: 

DAVID P. LITTELL, COMMISSIONER 

The term of this license shall be five (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: 11/23/05 

Date of application acceptance: 11/29/05 

Date filed with the Board of Envir0nmental Protection: 

This Order prepared by Lynn Ross, Bureau of Air Quality. 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license application, staff investigation reports and other 

documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 M.R.'S.A., 

Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Hancock Lumber Company, Inc. (Hancock) of Bethel, Maine has applied to 

renew their Air Emission License permitting the operation of emission sources 

associated with their sawmill. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Fuel Burning Equipment 

Equipment 

Maximum 

Capacity 

(MMBtu/hr) 

Boiler #1 25.05 

Boiler #2 13.3 

3.0 

Maximum 

Firin• Rate 

178.9 gal/hr 

Fuel Type, 

% sulfl•r 

#2 fuel oil, 0.35% 

Stack # 

4 

Planer Mill 

Gasifier 

Emergency 

Fire Pump 

1.33 

1.5 ton/hr 

(50% moisture) 

0.33 ton/hr 

(50% moisture) 

9.7 gal/hr 

wood waste 

wood waste 

diesel fuel, 0.05% 

3 

2 

Process Equipment 

Hancock operates seven kilns, various wood saws, planers and shaving/sawdust 

handling equipment. 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. Application Classification 

The application for Hancock does not include the licensing of increased emissions 

or the installation of new or modified equipment. Therefore, the license is 

considered to be a renewal of current licensed emission units only and has been 

processed through Chapter 115 of the Department's regulations. 

II. BEST PRACTICAL TREATMENT (BPT) 

Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical .Treatment 

(BPT), as defined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for existing emissions equipment means that method which controls or 

reduces emissions to the lowest possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emissions 

from the source being considered; and 

the economic feasibility for the type of establishment involved. 

B. Boiler #1 

Boiler #1 was installed in 1996 with a maximum design capacity of 

25.05 MMBtu/hr. It is therefore subject to the New Source Performance 

Standards (NSPS) Subpart Dc for steam generating units greater than 10 

MMBtu/hr manufactured after June 9, 1989. 

A summary of the BPT analysis for Boiler #1 is the following: 

1. The total fuel use for Boiler #1 shall not exceed 1,500,000 gal/year of#2 fuel 

oil, based on a 12 month rolling total, with a maximum sulfur content not to 

exceed 0.35% by weight. 

2. Chapter 106 regulates fuel sulfur content, however in this case a BPT analysis 

for SO2 determined a more stringent limit of 0.35% was appropriate and shall 

b,e used. 

3. Chapter 103 regulates PM emission limits. The PM10 limits are derived from 

the PM limits. 

4. NOx emission limits are based on data from similar #2 fired boilers of this size 

and age. 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

CO and VOC emission limits are based upon AP-42 data dated 9/98. 

Visible emissions from Boiler #1 shall not exceed 20% opacity on a six (6) 

minute block average, except for no more than one (1) six (6) minute block 

average in a continuous 3-hour period. 

C. Boiler #2 

When originally installed, Boiler #2 fired #2 fuel oil. Boiler #2 has since been 

retrofitted with a stoker to allow wood waste to be combusted. The oil firing 

capacity of the'boiler was not retained. Boiler #2 is equipped with a multicyclone 

for Control of particulate matter emissions. 

Boiler #2 was installed in 1998 with a maximum design capacity of 

13.3 MMBtu/hr. It is therefore subject to the New Source Performance Standards 

(NSPS) Subpart Dc for steam generating units greater than 10 MMBtu/hr 

manufactured after June 9, 1989. 

A summary of the BPT analysis for Boiler #2 is the following: 

1. The total fuel use for Boiler #2 shall not exceed 12,945 ton/year at 50% 

moisture (or equivalent) of wood waste, based on a 12 month rolling total. 

2. Hancock shall use the following formula for converting fuel use records to 

50% moisture: 

Tons Wood at 50% (Tons Wood at M%) x [(100-M)/50] 

where M the moisture content of the actual wood fired 

3. Hancock shall continuously operate the multicyclones on the emission from 

Boiler #2 when Boiler #2 is in operation. 

4. SO2 and VOC emission limits are based upon AP-42 data dated 2/99. 

5. Chapter 103 regulates PM emission limits. However in this case a BPT 

analysis for PM determined a more stringent limit of 0.25 lb/MMBtu was 

appropriate and shall be used. 

6. NO× and CO emission limits are based on data from similar wood fired boilers 

of this size and age. 

7. Visible emissions from Boiler #2 shall not exceed 30% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Eo 

D. Planer Mill Gasifier 

The Planer Mill Gasifier has a maximum design heat input of 3.0 MMBtu/hr 

firing 0.33 tons/hr of wood and sawdust at approximately 50% moisture. 

A summary of the BPT analysis for the Planer Mill Gasifier is the following: 

1. The total fuel use for the Planer Mill Gasifier shall not.exceed 2,920 ton/year 

at 50% moisture (or equivalent) of wood waste, based on a 12 month rolling 

total. 

2. Chapter 103 regulates PM emission limits. However in this case a BPT 

analysis for PM determined a more stringent limit of 0.20 lb/MMBtu was 

appropriate and shall be used. 

3. SOz, NOx, CO and VOC emission limits are based on data from a previous 

BACT analysis. 

4. Visible emissions from the Gasifier shall not exceed 20% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. 

Emergency Fire Pump 

Hancock operates an Emergency Fire Pump. 

"Emergency" is defined in Chapter 100 and throughout this document as: "... any 

situation arising from sudden and reasonably unforeseeable events beyond the 

control of the source, including acts of God, which situation requires immediate 

corrective action to restore normal operation, and that causes the source to exceed 

a technology based emission limitation under the license, due to unavoidable 

increases in emissions attributable to the emergency. An emergency shall not 

include noncompliance to the extent caused by improperly designed equipment, 

lack of preventative maintenance, careless or improper operation, or operator 

error." 

A summary of the BPT analysis for the Emergency Fire Pump (1.33 MMBtu/hr) 

is the following: 

1. The Emergency Fire Pump shall fire only diesel fuel with a maximum sulfur 

content not to exceed 0.05% by weight. 

2. The Emergency Fire Pump shall be limited to 500 hr/yr of operation based on 

a 12 month rolling total. Compliance shall be demonstrated by a written log 

of all operating hours. 

3. Chapter 106 regulates fuel sulfur content, however in this case a BPT analysis 

for SO2 determined a more stringent limit of 0.05% was appropriate and shall 

be used. 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 5 

Departmental 

Findings of Fact and Order 

Air Emission License 

4. The PM and PM•0 limits are derived from Chapter 103. 

5. NOx, CO, and VOC emission limits are based upon AP-42 data dated 10/96. 

6. Visible emissions from the Emergency Fire Pump shall not exceed 20% 

opacity on a six (6) minute block average, except for no more than two (2) six 

(6) minute block averages in a continuous 3-hour period. 

F. Kilns 

Hancock operates seven kilns for drying lumber. Heat for the kilns is provided by 

Boilers #1 or #2. Yearly throughput is limited to 30.0 million board feet per year 

based on a 12 month rolling total. 

Go Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed an opacity of 20%, except for no more than five (5) 

minutes in any one (1)-hour period. Compliance shall be determined by an 

aggregate of the individual fifteen (15)-second opacity observations which exceed 

20% in any one (1) hour. 

Ho Annual Emissions 

Hancock shall be restricted 

month rolling total: 

to the following annual emissions, based on a 12 

Total Licensed Annual Emission for the Facility 

Tons/year 

(used to calculate the annual license fee) 

Boiler #1 

Boiler #2 

Gasifier 

Fire Pump 

Kilns 

Total TPY 

10.5 

3.3 

0.6 

0.1 

14.5 

PM•0 

10.5 

3.3 

0.6 

0.1 

14.5 

SO2 

37.0 

0.1 

0.1 

0.1 

37.3 

NOx 

38.9 

4.0 

0.6 

5.9 

19.4 

CO 

3.8 

8.0 

2.7 

1.3 

15.8 

VOC 

0.2 

0.3 

0.1 

33.9 

35.0 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

III.AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a renewal source shall be determined on a case-by case basis. Modeling and 

monitoring are not required for a renewal if the total emissions of any pollutant released 

do not exceed the following: 

Pollutant 

PM 

PM10 

SO2 

NOx 

CO 

Tons/Year 

25 

25 

50 

100 

250 

Based on the above total facility emissions, Hancock is below the emissions level 

required for modeling and monitoring. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will .not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-1-71-M-R subject to the 

following conditions: 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(Title 38 MRSA §347-C). 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 

(2) 

(3) 

(4) 

(5) 

(6) 

(7) 

(8) 

Departmental 

Findings of Fact and Order 

Air Emission License 

(9) 

The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [MEDEP Chapter 115] 

(10) 

Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [MEDEP Chapter 115] 

The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. [MEDEP Chapter 115] 

The licensee_shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. [MEDEP Chapter 115] 

The license does not convey any property rights of any sort, or any exclusive 

privilege. [MEDEP Chapter 115] 

The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. [MEDEP Chapter 115] 

The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [MEDEP Chapter 115] 

The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [MEDEP Chapter 115] 

The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 8 

Departmental 

Findings of Fact and Order 

Air Emission License 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required bs; the Department, the 

licensee shall: 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuant to any other requirement of this license to perform stack testing. 

B. install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test completion. 

[MEDEP Chapter 115] 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

A. within thirty (30) days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60 or other method approved or required by the Department; and 

B. the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

C. the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

[MEDEP Chapter 115] 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [MEDEP Chapter 115] 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 9 

Departmental 

Findings of Fact and Order 

Air Emission License 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, Whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 115] 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. [MEDEP Chapter 115] 

SPECIFIC CONDITIONS 

(16) Boiler #1 

A. Total fuel use for Boiler #1 shall not exceed 1,500,000 gal/yr of #2 fuel oil 

with a maximum sulfur content not to exceed 0.35% by weight. Compliance 

shall be demonstrated by fuel records from the supplier showing the quantity 

of fuel delivered and the percent sulfur of the fuel. Records of annual fuel use 

shall be kept on a 12-month rolling total basis. [MEDEP Chapter 115, BPT] 

B. Emissions shall not exceed the following: 

Emission Unit Pollutant lb/MMBtu Origin and Authority 

Boiler # 1 PM 0.10 MEDEP Chapter 115, BPT 

C. Emissions shall not exceed the following [MEDEP Chapter 115, BPT]: 

Emission PM 

Unit (lb/hr) 

|oiler'•l 2.51 

PM10 

(lb/hr) 

2.51 

SO2 

(lb/hr) 

8.83 

NOx CO VOC 

0b/hr) (lb/hr) (lb/hr) 

9.27 9,89 0.04 

D. Visible emissions from Boiler #1 shall not exceed 20% opacity on a six (6) 

minute block average, except for no more than one (1) six (6) minute block 

average in a continuous 3-hour period. [MEDEP Chapter 101 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 10 

Departmental 

Findings of Fact and Order 

Air Emission License 

(17) Boiler #2 

A. Total fuel use for Boiler #2 shall not exceed 12,945 tons/yr at 50% moisture 

(or equivalent) of wood waste. Records of annual fueluse shall be kept on a 

12-month rolling total basis. [MEDEP Chapter 115, BPT] 

B. Hancock shall continuously operate the multicyclones on the emissions from 

Boiler #2 whenever Boiler #2 is in operation. [MEDEP Chapter 115, BPT] 

C. Emissions shall not exceed the following: 

Emission Unit Pollutant lb/MMBtu Origin and Authority 

Boiler #2 PM 0:25 MEDEP Chapter 115, BPT 

D. Emissions shall not exceed the following [MEDEP Chapter 115, BPT]: 

Emission 

Unit 

PM PM•0 

0b/hr) (lb/hr) 

3.33 3.33 

SO2 NOx 

(lb/hr) (lb/hr) 

0.11 3.99 

•CO 

(lb/hr) 

VOC 

(lb/hr) 

0.33 

Visible emissions from Boiler #2 shall not exceed 30% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. [MEDEP Chapter 101] 

(18) New Source Performance Standards for Dc Boilers 

Boilers #1 and #2 are subject to Federal New Source Performance Standards, 

Subpart Dc. Hancock shall comply with all requirements of 40 CFR Part 60, 

Subpart Dc including, but not limited to, the following: 

Hancock shall record and maintain records of the amounts bf each fuel 

combusted during each day. 

Hancock shall submit to EPA and the Department semi-annual reports. These 

reports shall include the calendar dates covered in the reporting period and 

records of fuel supplier certifications for Boiler #11 (The fuel supplier 

certification must contain the name of the oil supplier and a statement from 

the oil supplier that the oil complies with ASTM specifications for #2 fuel 

oil.) The semi-annual reports are due within 30 days of the end of each 6- 

month period. 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-I:71-M-R 11 

Departmental 

Findings of Fact and Order 

Air Emission License 

C. The following address •br EPA shall be used for any reports or notifications 

required to be copied to them: 

Compliance Clerk 

USEPA Region 1 

1 Congress Street 

Suite 1100 

Boston, MA 02114-2023 

(19) Planer Mill Gasifier 

A. Total fuel use for the Gasifier shall not exceed 2,920 tons/yr at 50% moisture 

(or equivalent) of wood waste. Records of annual fuel use shall be kept on a 

12-month rolling total basis. [MEDEP Chapter 115, BPT] 

B. Emissions shall not exceed the following: 

Emission .Unit 

Gasifier 

Pollutant 

PM 

lb/MMBtu 

0.20 

Origin and Authority 

MEDEP Chapter 115, BPT 

C. Emissions shall not exceed the following [MEDEP Chapter 1 ! 5, BPT]: 

Emission PM 

Unit 0b/hr) 

Gasifier 0.60 

PM10 S02 

(lb/hr) (lb/hr) 

0.60 0.12 

NOx CO VOC 

0b/hr) (lb/hr) (lb/hr) 

0.63 2.71 0.11 

(20) 

D. Visible emissions from the Gasifier shall not exceed 20% opacity on a six (6) 

minute block average, except for no more than two (2) six (6) minute block 

averages in a continuous 3-hour period. [MEDEP Chapter 115, BPT] 

Emergency Fire Pump 

A. Hancock shall limit the Emergency Fire Pump to 500 hr/yr of operation (based 

on a 12 month rolling total). An hour meter shall be maintained and operated 

on the Emergency Fire Pump. IMEDEP Chapter 115, BPT] 

B. A log documenting the dates, times, and reason of operation for the 

Emergency Fire Pump shall be kept. [MEDEP Chapter 115, BPT] 

C. The Emergency Fire Pump shall fire #2 fuel oil with a. sulfur limit not to 

exceed 0.05% by weight. Compliance shall be based on fuel records from the 

supplier showing the quantity of fuel delivered and the percent sulfur of the 

fuel. [MEDEP Chapter 115, BPT] 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 12 

Departmental 

Findings of Fact and Order 

Air Emission License 

D. Emissions shall not exceed the following [MEDEP Chapter 115, BPT]: 

(21) 

(22) 

(23) 

(24) 

Emission 

Unit 

Fire Pump 

PM 

(lb/hr) 

0.16 

eMlo 

0b/hr) 

0.16 

SO2 

(lb/hr) 

0.07 

NOx CO 

(lb/hr) 0b/hr) 

5.87 1.26 

VOC 

(lb/hr) 

0.47 

E. Visible emissions from the Emergency Fire Pump shall not exceed 20% 

opacity on a six (6) minute block average, except for no more than two (2) six 

(6) minute block averages in a continuous 3-hour period. 

[MEDEP Chapter 101 

Kilns 

A. Hancock shall not exceed a yearly throughput of 30.0 million board feet per 

year based on a 12 month rolling total. [MEDEP Chapter 115, BPT] 

B. Hancock shall keep monthly records of board feet processed. 

[MEDEP Chapter 115, BPT] 

Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed an opacity of 20%, except for no more than five (5) 

minutes in any one (1)-hour period. Compliance shall be determined by an 

aggregate of the individual fifteen (15)-second opacity observations which exceed 

20% in any one (1) hour. [MEDEP Chapter 101] 

Hancock shall notify the Department within 48 hours and submit a report to the 

Department on a quarterly basis if a malfunction or breakdown in any component 

causes a violation of any emission standard (Title 38 MRSA §605). 

Annual Emission Statement 

In accordance with MEDEP Chapter 137, the licensee shall annually report to the 

Department the information necessary to accurately update the State's emission 

inventory by means of: 

1) A computer program and accompanying instructions supplied by the 

Department; 

or 

2) A written emission statement containing the information required in 

MEDEP Chapter 137. 
Hancock Lumber Company, Inc. 

Oxford County 

Bethel, Maine 

A-1-71-M-R 13 

Departmental 

Findings of Fact and Order 

Air Emission License 

(25) 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 

The emission statement must be submitted in a timely manner as specified 

in Chapter 137. 

Payment of Annual License Fee 

Hancock shall pay the annual air emission license fee within 30 days of 

January31 st of each year. Pursuant to 38 MRSA §353-A, failure to pay this 

annual fee in the stated timeframe is sufficient grounds for revocation of the 

license under 38 MRSA §341-D, subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

DAY OF 2004, 

BY: 

DAWN R. GALLAGHER, COMMfSSIONER 

The term of this license shall be five (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt Of application: 9/9/04 

Date of application acceptance: 9/16/04 

Date filed with the Board of Environmental Protection: 

This Order prepared by Lynn Ross, Bureau of Air Quality. 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license application, staff investigation reports and other 

documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 M.R.S.A., 

Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

Introduction 

Katahdin Forest Products (KFP) of Oakfield, Maine has applied for a new Air 

Emission License permitting the operation of emission sources associated with 

their cedar log home manufacturing facility. 

B. Emission Equipment 

The following equipment is addressed in this air emission license: 

Fuel Burning Equipment 

Maximum Maximum 

Equipment Capacity Firing Rate 

(MMBtu/hr) l (tons/hr) 

Boiler #1 14.2 1.392 

Fuel Type 

Wood/ 

bark waste 

Post Comb. Stack 

Control 

Multicyclone 1 

Process Equipment 

Equipment 

Dry Kiln 

Paint Dip Tanks (2) 

Single Surface Planer 

1 x 3 Planer 

Planer 

Production Rate 

10,0 MMBF/year 3 

670 gallons/year 

Latex Primer & Stain 

0.005 MMBF/year 

1.5 MMBF/year 

3.4 MMBF/year 

Pollution Control 

Equipment 

None 

None 

Cyclone 

Cyclone 

Cyclone 

MMBtu/hr million British Thermal Units per hour 

2 Firing rate calculated based on wood at 43% moisture and with a higher heating value of 5,130 Btu/hr. 

MMBF/year million board feet per year 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 

KFP also operates aParts Washer. 

Departmental 

Findings of Fact and Order 

Air Emission License 

KFP also operates several small wood stoves and heating units that are considered 

insignificant for the purposes of this license. 

Co Application Classification 

KFP has operated a log home manufacturing facility at the present site since 1973. 

The facility has not been subject to air emissions licensing requirements due to 

the lack of any single large emission source. The various operations are spread 

over a large site, and heat has been provided with small individual heating 

systems. KFP intends to improve its profitability by installing a central biomass 

boiler on the site to produce steam and hot water for distribution to various site 

operations for both space heating and kiln drying. A new .source is considered a 

major source based on whether or not expected emissions exceed the "Significant 

Emission Levels" as defined in the Department's regulations. Emissions for the 

new source are determined by the maximum future license allowed emissions, as 

follows: 

Pollutant 

PM 

Max. Future 

License 

15.55 

Sig. Level 

100 

PM•0 15.55 100 

SO2 

NOx 

1.55 

13.68 

37.32 

3.66 

CO 

VOC 

100 

100 

100 

5O 

The Department has determined the facility is a minor source and the application 

has been processed through Chapter 115 of the Department's regulations 

II. BEST. PRACTICAL TREATMENT (BPT) 

Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. BPT for new sources and 

modifications requires a demonstration that emissions are receiving Best 

Available Control Technology (BACT), as defined in Chapter 100 of the 

Department's regulations. BACT is a top-down approach to selecting air 

emission controls considering economic, environmental and energy impacts. 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

Bo Process Description 

KFP's main business is the sawing and manufacture of pre-cut log homes for 

delivery to sites across the United States. Raw materials, including log length 

cedar, pine and spruce logs are trucked to sawmills by forklift, where they are 

debarked, sawed to length, ripped to the appropriate cross section, and stockpiled 

for drying and further milling and machining. The sawmill waste is hogged and 

stockpiled. Because many of the operations are conducted in separate buildings, the products are moved from building to building by forklift. The log cabin wall 

stock (typically cedar, but optionally pine) is milled for tongue and groove 

construction and appropriate end lap in the recently completed automated house 

line, a state-of-the-art computer controlled facility. Other components of the log 

home package, including cedar paneling, cedar decking and spruce roof purlins 

are manufactured on-site. Additional items such as windows, doors, insulation, 

and roofing materials are brought to the site for packaging with the complete 

home kit to be shipped to the builder. 

Smaller sections of the cedar log which remain after sawing the cabin stock are 

processed into cedar fencing, and shipped to various dealers for resale. The 

smaller scraps of waste wood are utilized by Cedar Ideas, Inc., a separate 

company with common ownership and management located adjacent to the KFP 

site. Cedar Ideas uses the wood scraps to manufacture various specialty items like 

window boxes, planters, birdhouses, and assorted novelty products. Many of the 

Cedar Ideas products are painted or finished in a dipping process. All remaining 

wood by-products, such as sawdust, bark, and shavings will be fired in the 

biomass boiler to generate heat for kiln drying and other energy needs. 

Boiler #1 

Boiler #1 is a used wood fired low pressure steam boiler purchased by KFP from 

the now defunct Houlton International Corp. The boiler was installed by Houlton 

International Corp in 1991 and last licensed in 2002 (License A-227-71-F-R, 

Boiler 103). The unit is a Superior Boiler Model 3-SF-2001-515-M, Low 

Pressure Steam Boiler manufactured in 1991. It has a maximum capacity of 14.2 

MMBtu/hr firing wood with a firing rate of 1 •39 tons/hour, based on wood with a 

moisture content of 43%. KFP plans to custom build a mechanical system to feed 

fuel into the boiler. The boiler will exhaust through a Zum/Clarage model 

MTSA-12-9CYT-A-N/RSTD multiclone. The same mechanical collector was 

used at the Houlton International installation. KFP will also use the same stack 

from the previous installation; it is 1.83 feet inside-diameter and will terminate 76 

feet above ground level. 

Boiler #1 was manufactured in 1991, and is therefore subject to the New Source 

Performance Standards (NSPS) Subpart Dc for steam generating units greater 

than 10 MMBtu/hr manufactured after June 9, 1989. 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 4 

Departmental 

Findings of Fact and Order 

Air Emission License 

Fuel for the boiler will consist of cedar waste from the 10-foot and 6-foot 

sawmills. The waste stream consists of a mixture of hogged slabs (with bark) and 

sawdust. The remaining waste stream from the various mill operations consists of 

a mixture of shavings, chips, sawdust and bark and is an estimated 50/50 mixture 

of air dried and kiln dried material. The facility tested its waste wood for 

moisture content between June 2004 and March 2005 and found an average fuel 

moisture content of 43%. 

A summary of the BACT analysis for Boiler #1 (14•2 MMBtu/hr) is the 

following: 

1. Chapter 103 regulates PM emission limits, however in this case the BACT 

limit of 0.25 lb/MMBtu is more stringent and shall be used. The PM10 limit is 

derived from the PM limit. 

2. The SO2, NOx, CO and VOC emission limits are based on AP-42 data dated 

9/03. 

3. Visible emissions from Boiler #1 shall not exceed 30% opacity on a 6-minute 

block average basis, except for no more than two 6-minute block averages in a 

3-hour period. 

Do Wood Drying Kiln 

KFP operates a kiln to dry cedar and pine lumber. The facility is licensed to 

process 10.0 million board feet per year through the wood drying kiln. VOC 

emissions released from the kiln during the wood drying process have been 

estimated using data from studies conducted by the National Council of the Paper 

Industry for Air and Stream Improvement, Inc. (NCASI) and the University of 

Maine. The kiln dries cedar species nearly exclusively, therefore the cedar 

emission factor was used to estimate VOC emissions from the kiln. KFP shall 

maintain records of wood throughput in the kilns, on a 12-month rolling basis. 

Eo Paint Dip Tanks 

KFP operates two Paint Dip Tanks, which are used to coat the novelty wood 

products produced by Cedar Ideas, Inc. Latex Primer and Acrylic Latex Stain are 

the coatings applied in the dip tanks. Both products contain small amounts of 

VOC and HAP. KFP shall not exceed 2.0 tons/year 0f VOC or 1.0 tons/year of 

HAP emissions from the Paint Dip Tanks, on a 12-month rolling total. KFP shall 

maintain records of the amount• of Latex Primer and Acrylic Latex Stain used and 

shall calculate VOC and HAP emissions on a monthly and a 12-month rolling 

basis, assuming the VOC and HAP contents from the materials' Material Safety 

Data Sheets (MSDS) and that 100% of the VOC and HAP emitted volatizes to the 

atmosphere. 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 5 

Departmental 

Findings of Fact and Order 

Air Emission License 

Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed 20% opacity except for no more than five minutes in 

any 1-hour period. Compliance shall be determined by an aggregate of the 

individual 15-second opacity observations which exceed 20% in any one hour. 

Go Process Emissions 

Visible emissions from any general process source shall not exceed 20% opacity 

on a 6-minute block average basis, except for no more than one (1) six (6) minute 

block average in a l-hour period. 

H. Parts Washer 

The Parts Washer shall meet the requirements of MEDEP Chapter 130. 

Annual Emissions 

KFP shall be restricted to the following annual emissions, based on a 12 month 

rolling total: 

Total Licensed Annual Emission for the Facility 

Tons/year 

(used to calculate the annual license fee) 

Boiler #1 

Wood Kilns 

Paint Dip Tanks 

Total TPY 

PM 

15.55 

15.55 

PM10 

15.55 

15.55 

SO2 

1.55 

1.55 

NOx 

13.68 

13.68 

CO 

37.32 

37.32 

VOC 

1.06 

0.6 

2.0 

KFP shall not exceed 1.0 ton/year of total HAP from the Paint Dip Tanks. 

III.AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a renewal source shall be determined on a case-by case basis. Based on the 

above total facility emissions, KFP is below the emissions level required for modeling and monitoring. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

The Department hereby grants Air Emission License A-939-71-A-N subject to the 

following conditions: 

Severabilitv. The invalidity or unenforceability of any provision, or part thereof, of this 

License shall not affect the remainder of the provision or any other provisions. This 

License shall be construed and enforced in all respects as if such invalid or unenforceable 

provision or part thereof had been omitted. 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(38 MRSA §347-C). 

(2) The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. [MEDEP Chapter 115] 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. [MEDEP Chapter 115] 

(4) The licensee shall establish and maintain a continuing program of best 

management practices forsuppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. [MEDEP Chapter 115] 

The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. [MEDEP Chapter 115] 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. [MEDEP Chapter 115] 

(7) The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. [MEDEP Chapter 115] 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 7 

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(8) 

(9) 

(10) 

(11) 

(12) 

The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. [MEDEP Chapter 115] 

The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. [MEDEP Chapter 115] 

The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. [MEDEP Chapter 115] 

In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

A. perform stack testing to demonstrate compliance with the applicable emission 

standards under circumstances representative of the facility's normal process 

and operating conditions: 

1. within sixty (60) calendar days of receipt of a notification to test from the 

Department or EPA, if visible emissions, equipment operating parameters, 

staff inspection, air monitoring or other cause indicate to the Department 

that equipment may be operating out of compliance with emission 

standards or license conditions; or 

2. pursuant to any other requirement of this license to perform stack testing. 

B. install or make provisions to install test ports that meet the criteria of 40 CFR 

Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

C. submit a written report to the Department within thirty (30) days from date of 

test completion. 

[MEDEP Chapter 115] 

If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

A. within thirty (30)days following receipt of such test results, the licensee shall 

re-test the non-complying emission source under circumstances representative 

of the facility's normal process and operating conditions and in accordance 

with the Department's air emission compliance test protocol and 40 CFR Part 

60. or other method approved or required by the Department; and 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 8 

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B. the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is demonstrated 

under normal and representative process and operating conditions, except to 

the extent that the facility can prove to the satisfaction of the Department that 

there were intervening days during which no violation occurred or that the 

violation was not continuing in nature; and 

the licensee may, upon the approval of the Department following the 

successful demonstration of compliance, at alternative load .conditions, operate 

under such alternative load conditions on an interim basis prior to a 

demonstration of compliance under normal and representative process and 

operating conditions. 

[MEDEP Chapter 115] 

Co 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. [MEDEP Chapter 115] 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

[MEDEP Chapter 115] 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. [MEDEP Chapter 115] 

SPECIFIC CONDITIONS 

(16) Boiler #1 

A. Boiler #1 shall fire wood and bark waste. [MEDEP Chapter 115, BACT] 

B. Emissions from Boiler #1 shall be exhausted through a multiclone. [MEDEP 

Chapter 115, BACT] 

C. Emissions shall not exceed the following: 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 

Departmental 

Findings of Fact and Order 

Air Emission License 

Emission Unit Pollutant lb/MMBtu Origin and Authority 

Boiler #1 PM 0.25 MEDEP Chapter .103, BACT 

D. Emissions shall not exceed the following [MEDEP Chapter 115, BACT]: 

(17) 

(18) 

(19) 

Emission 

Unit 

PM PM10 

0b/hr) (lb/hr) 

3.55 3.55 

SO2 NOx 

(lb/hr) 0b/hr) 

0.36 3.12 

CO VOC 

(lb/hr) (lb/hr) 

:• •.•:• 0.24 

Eo Visible emissions from Boiler #1 shall not exceed 30% opacity on a 6-minute 

block average basis, except for no more than two 6-minute block averages in a 

3-hour period. [MEDEP Chapter 101 

New Source Performance Standards 

Boiler #1 is subject to Federal New Source Performance Standards, Subpart De. 

KFP shall comply with all requirements of 40 CFR Part 60, Subpart Dc including, 

but not limited to, the following: 

A. KFP shall submit notification to EPA and the Department of the date of 

construction, anticipated start-up, and actual start-up. This notification shall 

include the design heat input capacity of the boiler and the type of fuel to be 

combusted.. 

B. KFP shall record and maintain records of the amount of fuel combusted 

during each day. These records shall be maintained by KFP for a period of 

two years following the date of the record. 

Wood Drying Kiln 

Yearly throughput is limited to 10 million board feet per year based on a 12- 

month rolling total. Compliance shall be demonstrated through kiln loading 

records. [MEDEP Chapter 115, BACT] 

Paint Dip Tanks 

A. KFP shall not exceed 2.0 tons/year of VOC or 1.0 tons/year of HAP emissions 

from the Paint Dip Tanks, on a 12-month rolling total. [MEDEP Chapter 115, 

BACT] 

B. KFP shall maintain records of the amount of VOC- and HAP-containing 

coating used in the Paint Dip Tanks. {MEDEP Chapter 115, BACT] 

C. KFP shall calculate VOC and HAP emissions from the Paint Dip Tanks on a 

monthly and 12-month rolling basis, assuming the VOC and HAP contents 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 10 

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from the coatings' Material Safety Data Sheets (MSDS) and that 100% of the 

VOC and HAP volatizes to the atmosphere. [MEDEP Chapter 115, BACT] 

(20) Fugitive Emissions 

Visible emissions from a fugitive emission source (including stockpiles and 

roadways) shall not exceed 20% opacity, except for no more than five minutes in 

any 1-hour period. Compliance shall be determined by an aggregate of the 

individual 15-second opacity observations which exceed 20% in any one hour. 

[MEDEP Chapter 101 ] 

(21) General Process Sources 

Visible emissions from any general process source shall not exceed 20% opacity 

on a 6-minute block average basis, except for no more than one 6-minute block 

average in a l-hour period. [MEDEP Chapter 101 

(22) Parts Washer 

Parts washers at KFP are subject to MEDEP Chapter 130. 

A. KFP shall keep records of the amount of solvent added to each parts washer. 

[MEDEP Chapter 115, BPT] 

B. The following are exempt from the requirements of• Chapter 130 [MEDEP 

Chapter 130]: 

1. Solvent cleaners using less than two liters (68 oz) of cleaning solvent with 

a vapor pressure of 1.00 mmHg, or less, at 20 C (68 F); 

2. Wipe cleaning; and, 

3. Cold cleaning machines using solvents containing less than or equal to 5% 

VOC by weight. 

C. The following standards apply to remote.reservoir cold cleaning machines that 

are applicable sources under Chapter 130. 

1. KFP shall attach a permanent conspicuous label to each unit summarizing 

the following operational standards [MEDEP Chapter.130]: 

(i) Waste solvent shall be collected and stored in closed containers. 

(ii) Cleaned parts shall be drai/aed of solvent directly back to the cold 

cleaning machine by tipping or rotating the part for at least 15 

seconds or until dripping ceases, whichever is longer. 

(iii) Flushing of parts shall be performed with a solid solvent spray that is 

a solid fluid stream (not a fine, atomized or shower type spray) at a 

pressure that does not exceed 10 psig. Flushing shall be performed 

only within the freeboard area 0fthe cold cleaning machine. 

(iv) The cold cleaning machine shall not be exposed to drafts greater than 

40 meters per minute when the cover is open. 

(v) Sponges, fabric, wood, leather, paper products and other absorbent 

materials shall not be cleaned in the degreaser. 

(vi) When a pump-agitated solvent bath is used, the agitator shall be 

operated to produce no observable splashing of the solvent against 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 11 

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Findings of Fact and Order 

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the tank walls or the parts being cleaned. Air agitated solvent baths 

may not beused. 

(vii) Spills during solvent transfer shall be cleaned immediately. Sorbent 

material shall be immediately stored in covered containers. 

(viii) Work area fans shall not blow across the opening of the degreaser 

unit. 

(ix) The solvent level shall not exceed the fill line. 

The remote reservoir cold cleaning machine shall be equipped with a 

perforated drain with a diameter of not more than six inches. [MEDEP 

Chapter 130, BPT] 

(23) KFP shall notify the Department within 48 hours and submit a report to the 

Department on a quarterly basis if a malfunction or breakdown in any component 

causes a violation of any emission standard (38 MRSA §605). 

(24) Annual Emission Statement 

In accordance with MEDEP Chapter 137, the licensee shall annually report to the 

Department the information necessary to accurately update the State's emission 

inventory by means of: 

1) A computer program and accompanying instructions supplied by the 

Department; 

or 

2) A written emission statement containing the information required in 

MEDEP Chapter 137. 

Reports and questions should be directed to: 

Attn: Criteria Emission Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207)287-2437 

The emission statement must be submitted by July 1 or as otherwise 

specified in Chapter 137. 

(25) Air Toxics Emission Statement 

If KFP exceeds the thresholds for HAPs listed in Appendix A of MEDEP Chapter 

137 in an inventory year, in accordance with MEDEP Chapter 137 the licensee 

shall report, no later than July 1 every three years (2005, 2008, 2011, etc.) or as 

otherwise stated in Chapter 137, the information necessary to accurately update 
Katahdin Forest Products 

Aroostook County 

Oakfield, Maine 

A-939-71-A-N 12 

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the State's toxic air pollutants emission inventory by means of a computer 

program supplied by the Department or a written emission statement containing 

the information required in MEDEP Chapter 137. 

NOTE: Based on AP-42 emission factors for fuel burning equipment, KFP will 

most likely exceed the Chapter 137 thresholds of HAPs based on fuel burning 

alone should the facility exceed the firing of 250 tons of wood waste (50% 

moisture) in a calendar year. 

Reports and questions should be directed to: 

HAP Inventory Coordinator 

Maine DEP 

Bureau of Air Quality 

17 State House Station 

Augusta, ME 04333-0017 

Phone: (207) 287-2437 [MEDEP Chapter 137] 

(26) Payment of Annual License Fee 

KFP shall pay the annual air emission license fee within 30 days of May 31 st of 

each year. Pursuant to 38 MRSA §353-A, failure to pay this annual fee in the 

stated timeframe is sufficient grounds for revocation of the license under 38 

MRSA §341-D, subsection 3: 

DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

2006. 

BY: 

DAVID P. LITTELL, COMMISSIONER 

The term of this license shall be five (5) years from the signature date above. 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: February 22, 2006 

Date of application acceptance: March 1, 2006 

Date filed with the Board of Environmental Protection: 

This Order prepared by Rachel E. Pilli.ng, Bureau of Air Quality. 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license renewal application, staff investigation reports 

and other documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 

M.R.S.A., Section 344 and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Lavalley Lumber Company, LLC (Lavalley) of Sanford, Maine has applied to 

renew their Air Emission License permitting the operation of emission sources 

associated with their Sanford, Maine wood products facility. 

B. Emission Equipment 

Lavalley is authorized to operate the following equipment: 

Fuel Burning Equipment 

Equipment 

•'ler #1 

Boiler #2 

Maximum 

Capacity 

0VIMBtu/hr) 

33.5 

14.6 

Fuel Type, Maximum Date of 

%Sulfur Firing Rate Manufacture Stack # 

3.7 ton/hr 1980 #1 

#6 o•i, 01•6/• •97.5 gal/hr 1973 #2 

Electrical Generation Equipment 

Equipment 

Diesel Generator 

Power Firing 

Output Fuel Type, Rate 

(kW) % sulfur (•al/hr) 

350 Diesel, 0.05% 24.4 

Process Equipment 

Equipment 

Whole Tree Chipper 

Power 

•Output 

650 

Fuel Type, 

% sulfur 

Diesel, 0.05% 

Firing Rate 

(aal/hr) 

32.6 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

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C. Application Classification 

The application for Lavalley Lumber Company, LLC of Sanford, Maine does not 

include the licensing of increased emissions or the installation of new or modified 

equipment. Therefore, the license is considered to be a renewal of current 

licensed emission units only. 

II. BEST PRACTICAL TREATMENT (BPT) 

A. Introduction 

In order to receive a license the applicant must control emissions from each unit 

to a level considered by the Department to represent Best Practical Treatment 

(BPT), as defined in Chapter 100 of the Department regulations. Separate control 

requirement categories exist for new and existing equipment as well as for those 

sources located in designated non-attainment areas. 

BPT for existing emissions equipment means that method which controls or 

reduces emissions to the lowest possible level considering: 

the existing state of technology; 

the effectiveness of available alternatives for reducing emission 

from the source being considered; and 

the economic feasibility for the type of establishment involved. 

B. Facility Description 

Lavalley is a lumber and building materials manufacturing facility located in 

Sanford, Maine. Emission sources at the facility include: a wood-fired boiler and 

associated fuel handling equipment, wood sawing and milling machines, an oil 

fired boiler and associated equipment, a diesel generator and a diesel powered 

whole tree chipper. 

C. Boiler #1 

Lavalley operates Boiler #1 to satisfy heating and hot water needs for their wood 

product manufacturing facility. Boiler #1 is a dutch oven style boiler with a 

design heat input capacity of 33.5 MMBtu/hr firing wood waste and a maximum 

design steam flow rate of 27,000 pounds of saturated steam at. 175 psia per hour. 

Boiler #1 is equipped with two multicyclone mechanical dust separators for 

particulate control. Boiler #1 was manufactured in 1980 and is therefore not 

subject to EPA New Source Performance Standards (NSPS) Subpart Dc 

(Standards of Performance for Small Industrial-Commercial-Institutional Steam 

Generating Units applicable to boilers with a heat input of greater than 10 

MMBtu/hr and manufactured after June 9, 1989). 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

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Lavalley is limited to firing no more than 29,000 tons of 50% moisture wood fuel 

or equivalent per year based on a twelve-month rolling total in Boiler #1. In order 

to demonstrate compliance with the wood fuel use restriction for Boiler #1, 

Lavalley shall maintain a wood fuel use log indicating the twelve-month rolling 

total wood fuel use in Boiler #1. 

A summary of the BPT analysis for Boiler #1 (33.5 MMBtu/hr) is as follows: 

1. PM/PM•0 emission limits are based upon MEDEP Chapter 103. 

2. SO2, N0x, CO and VOC emission limits are based upon AP-42 data dated 

7/01 for wood combustion. 

3. Visible emissions from stack #1 shall not exceed 30% opacity on a 6-minute 

block average, except for no more than two 6-minute block averages in a 

3-hour period. 

D. Fuel Handling 

Lavalley utilizes a pneumatic blower system to transfer waste wood from the 

wood processing areas to a dust cyclone, designated Cyclone#l, which drops the 

wood waste onto a drag chain conveyor to be dumped into the Boiler #1 fuel bin. 

Waste wood is then pulled out of the fuel bin by conveyor to Boiler #1 as fuel. 

Lavalley also utilizes an outside fuel shed for fuel storage. Wood fuel is loaded 

and unloaded into and out of the fuel shed by bucket loader. 

In accordance with Chapter 101, Section 2(B)(3)(d) of the Department's 

regulations, general process emissions from the waste wood handling system 

which includes the waste wood blower system and conveyor system, the dust 

cyclone (Cyclone #1) and the waste wood fuel bin and shed, shall not exceed an 

opacity of 20% on a 6-minute block average basis, except for no more than one 

6-minute block average in a 1-hour period. 

Lavalley shall .establish a system of maintenance, inspection and repair for the 

waste wood handling system, which shall allow for a monthly inspection of the 

system and Lavalley shall document compliance by means of a maintenance, 

inspection and repair log. 

E. Boiler #2 

Lavalley also operates Boiler #2 to satisfy heating and hot water needs for their 

wood product manufacturing facility. Boiler #2 is a Clever Brooks manufactured 

boiler with a design heat input capacity of 14.6 MMBtu/hr firing #6 fuel oil with a 

sulfur content of no greater than 0.5% sulfur by weight. 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

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Boiler #2 was manufactured in 1973 and is therefore not subject to EPA New 

Source Performance Standards (NSPS) Subpart Dc (Standards of Performance for 

Small Industrial-Commercial-Institutional Steam Generating Units applicable to 

boilers with a heat input of greater than 10 MMBtu/hr and manufactured after 

June 9, 1989). 

Lavalley is limited to firing no more than 450,000 gallons of #6 fuel oil with a 

sulfur content of no greater than 0.5% sulfur by weight in Boiler #2. In order to 

demonstrate compliance with the fuel oil use restriction for Boiler #2, Lavalley 

shall maintain a fuel oil use log indicating the twelve-m0nth rolling total fuel oil 

use in Boiler #2 and including supplier certification indicating the sulfur content 

of the fuel. 

A summary of the BPT analysis for Boiler #2 (14.6 MMBtu/hr)is as follows: 

1. PM/PM10 emission limits are based upon MEDEP Chapter 103. 

2. SO2, NOx, CO and VOC emission limits are based upon AP-42 data dated 

10/96 for oil combustion. 

3. Visible emissions from stack #2 shall not exceed 20% opacity on a 6-minute 

block average, except for no more than two 6-minute block averages in a 

3-hour period. 

F. Diesel Generator 

Lavalley utilizes a 350 kW diesel generator set to satisfy back-up and emergency 

power for the facility. As previously licensed, the diesel generator shall meet 

BPT through the firing of no greater than 25,000 gallons of diesel fuel with a 

sulfur content of no greater than 0.05% sulfur by weight. Emissions calculations 

for the diesel generator were based on AP-42 factors dated 10/96. 

In order to demonstrate compliance with the fuel oil use restriction for the diesel 

generator, Lavalley shall maintain a fuel oil use log indicating the twelve-month 

rolling total fuel oil use in the diesel generator and including, supplier certification 

iiadicating the diesel fuel oil sulfur content. 

In accordance with Chapter 101, Section 2(B)(1)(f) of the Department's 

regulations, visible emissions from the diesel generator set shall not exceed an 

opacity of 30% on a 6-minute block average basis, except for no more than two 

6-minute block averages in a 3-hour period. 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

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G. Whole Tree Chipper 

Lavalley utilizes a whole tree chipper powered by a diesel engine rated at 650 

horsepower. As previously licensed, the whole tree chipper engine shall meet 

BPT through the firing of no greater than 20,500 gallons of diesel fuel with a 

sulfur content of no greater than 0.05% sulfur by weight. Emissions calculations 

for the whole tree chipper diesel unit are based on AP-42 factors dated 10/96. 

In order to demonstrate compliance with the fuel oil use restriction for the whole 

tree chipper engine, Lavalley shall maintain a fuel oil use log indicating the 

twelve-month rolling total fuel oil use in the whole tree chipper engine and 

including supplier certification indicating the #2 fuel oil sulfur content. 

In accordance with Chapter 101, Section 2(B)(1)(f) of the Department's 

regulations, visible emissions from the whole tree chipper engine exhaust unit 

shall not exceed an opacity of 30% on a 6-minute block average basis, except for 

no more than two 6-minute block averages in a 3-hour period. 

In accordance with Chapter 101, Section 2(B)(3)(d) of the Department's 

regulations, general process emissions from the wood chipping process shall not 

exceed an opacity of 20% on a 6-minute block average basis, except for no more 

than one 6-minute block average in a 1-hour period. 

H. Wood Drying Kilns 

Lavalley makes use of 6 wood drying kilns to dry lumber produced at their 

facility. Lavalley utilizes four box kilns with volumes of 60,000 boardfeet (BF) 

each and two box kilns with volumes of 30,000 BF each. Annual throughput for 

the Lavalley wood drying kilns is approximately 15.0 million boardfeet (MMBF) 

per year. Lavalley predominantly dries Eastern White Pine. Using the emission 

factor of 2.26 pounds of VOC per 1000board feet for white pine and the current 

annual drying production from the Lavalley kilns of 15.0 MMBF per year, 

Lavalley emits approximately 2.8 tons of VOC per year from the kiln drying 

process. 

To allow for production flexibility, Lavalley shall be restricted to 25.0 tons of 

VOC emissions per year from kiln drying operations based on a twelve-month 

rolling total. To demonstrate compliance, Lavalley shall maintain a record of 

wood drying, which shall include the quantity of wood dried in the kilns 

indicating species and drying dates and VOC emissions calculations based on the 

amount of wood dried and the emission factor of 2.26 pounds of VOC per 1000 

BF of eastern white pine as indicated below. 

Annual VOC emissions (in tons) Boardfeet of eastern white pine dried x 2.26 pounds / 

1000 BF of eastern white pine / 2000 lbs per ton 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

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The wood drying record shall be maintained on a monthly as well as a 

twelve-month rolling total. 

Visible emissions from potential sources of fugitive particulate matter emissions, 

including material stockpiles and unpaved roadways, shall not exceed an opacity 

of 20%, except for no more than 5-minutes in any 1-hour period. Compliance 

shall be determined by an aggregate of the individual 15-second opacity 

observations which exceed 20% in any 1-hour. 

J. Annual Emission Restrictions 

Lavalley shall be .assessed fees based on the following: 

Pollutant 

PM 

PM10 

SO2 

NOx 

CO 

VOC 

Tons/Year 

61.6 

61.6 

21.1 

92.0 

82.3 

28.8 

III. AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a renewal source shall be determined on a case-by case basis. Based on the 

information available in the file, and the similarity to existing sources, Maine Ambient 

Air Quality Standards (MAAQS) will not be violated by this source and modeling and 

monitoring are not required for a renewal. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants Air Emission License A-24-71-M-R subject to the 

following conditions: 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

STANDARD CONDITIONS 

(1) 

(2) 

(3) 

(4) 

(5) 

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Findings of Fact and Order 

Air Emission License 

(6) 

(7) 

Employees. and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions 

(Title 38 MRSA §347-C). 

(8) 

The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. 

Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. 

The licensee shall establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive 

dust, and shall submit a description of the program to the Department upon 

request. 

The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 M.R.S.A. §353. 

The license does not convey any property rights of any sort, or any exclusive 

privilege. 

The licensee shall maintain and operate all emission units and air pollution 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. 

The licensee shall maintain sufficient records to accurately document compliance 

with emission standards and license conditions and shall maintain such records 

for a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

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(9) The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for a renewal of a license or amendment shall not stay 

any condition of the license. 

(10) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

(i) perform stack testing to demonstrate compliance with the applicable 

emission standards under circumstances representative of the facility's 

normal process and operating conditions: 

a. within sixty (60) calendar days of receipt of a notification to test 

from the Department or EPA, if visible emissions, equipment 

operating parameters, staff inspection, air monitoring or other 

cause indicate to the Department that equipment may be operating 

out of compliance with emission standards or license conditions; or 

b. pursuant to any other requirement of this license to perform stack 

testing. 

(ii) install or make provisions to install test ports that meet the criteria of 40 

CFR Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

(iii) submit a written report to the Department within thirty (30) days from date 

of test completion. 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

(i) within thirty (30) days following receipt of such test results, the licensee 

shall re-test the non-complying emission source under circumstances 

representative of the facility's normal process and operating conditions 

and in accordance with the Department's air emission compliance test 

protocol and 40 CFR Part 60 or other method approved or required by the 

Department; and 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(ii) 

(iii) 

the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is 

demonstrated under normal and representative process and operating 

conditions, except to the extent that the facility can prove to the 

satisfaction of the Department that there were intervening days during 

which no violation occurred or that the violation was not continuing in 

nature; and 

the licensee may, upon the approval of.the Department following the 

successful demonstration of compliance at alternative load conditions, 

operateunder such alternative load conditions on an interim basis prior to 

a demonstration of compliance under normal and representative process 

and operating conditions. 

(13) Notwithstanding any other provisions in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emission and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2). days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

(15) Upon written request from the Department, the licensee shall establish and 

maintain such records, make such reports, install, use and maintain such 

monitoring equipment, sample such emissions (in accordance with such methods, 

at such locations, at such intervals, and in such a manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. 

SPECIFIC CONDITIONS 

(16) Boiler #1 

Lavalley is limited to firing no more than 29,000 tons of wood fuel per year in 

Boiler #1 based on a twelve-month rolling total. Lavalley shall maintain fuel 

use records on a monthly and twelve-month rolling total basis. [MEDEP 

Chapter 115, BPT] 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

) 

) 

) 

10 

Departmental 

Findings of Fact and Order 

Air Emission License 

B. Boiler #1 shall not exceed the following emission limits: 

Equipment PM 

lb/MMBtu 0.44 

•l•oiler #1 lb/hr 14.7 

MEDEP Chapter 103 and 115, BPT] 

PMlo SO2 NOx •0 VOC 

14.7 0.8 16.4 •...A 1.3 

C. Visible emissions from stack #1 shall not exceed 30% opacity on a 6-minute 

block average, except for no more than two 6-minute block averages in a 

3-hour period. [MEDEP Chapter 101 

(17) Fuel Handling 

Visible emissions from the waste wood handling system which includes the 

waste wood blower system and conveyor system, the dust cyclone 

(Cyclone #1) and the waste wood fuel bin and shed, shall not exceed an 

opacity of 20% on a 6-minute block average basis, except for no more than 

one 6-minute block average in a 1-hour period. [MEDEP Chapter 101 

Bo Lavalley shall establish a system of maintenance, inspection and repair for the 

waste wood handling System, which shall allow for a monthly inspection of 

the system. [MEDEP Chapter 115, BPT] 

Co Lavalley shall document compliance by means of a maintenance, inspection 

and repair log. Lavalley shall inspect operations of the wood chip and wood 

dust handling system, once per month and record findings in the maintenance, 

inspection and repair log. [MEDEP Chapter 115, BPT] 

(18) Boiler #2 

A. Lavalley is limited to firing no more than 450,000 gallons of #6 fuel oil with a 

sulfur content of no greater than 0.5% sulfur by weight in Boiler #2. 

In order to demonstrate compliance with the fuel oil use restriction for 

Boiler#2, Lavalley shall maintain a fuel oil use log indicating the 

twelve-month rolling total fuel oil use in Boiler #2 and including supplier 

certification indicating the #6 fuel oil sulfur content. 

[MEDEP Chapter 115, BPT] 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

) 

) 

) 

11 

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Findings of Fact and Order 

Air Emission License 

C. Boiler #2 shall not exceed the following emission limits: 

Equipment PM PM10 SO2 NOx CO .VOC 

lb/MMBtu 0.12 

Boiler #2 lb/hr 1.8 1.8 7.6 7.3 0.5 0.1 

[MEDEP Chapter 103 and 115, BPT] 

D. Visible emissions from stack #1 shall not exceed 20% opacity on a 6-minute 

block average, except for no more than two 6-minute block averages in a 

3-hour period. [MEDEP Chapter 101 

(19) Ash from Boiler #1 and #2 shall be disposed of in accordance with the Bureau of 

Remediation and Waste Management (BRWM). Ash shall be sufficiently 

conditioned with water or transported in sealed containers so as to prevent 

fugitive emissions. 

(20) Diesel Generator 

mo The diesel generator shall be limited to firing no greater than 25,000 gallons 

per year of diesel fuel with a sulfur content of no greater than 0.05% sulfur by 

weight based on a twelve-month rolling total. [MEDEP Chapter 115, BPT] 

Bo In order to demonstrate compliance with the fuel oil use restriction for the 

diesel generator, Lavalley shall maintain a fuel oil use log indicating the 

twelve-month rolling total fuel oil use in the diesel generator and including 

supplier certification indicating the diesel fuel oil sulfur content. 

[MEDEP Chapter 115, BPT] 

C. The diesel generator shall not exceed the following emission limits: 

Equipment PM PM10 SO2 NOx CO VOC 

lb/MMBtu 0.12 

Boiler #2 lb/hr 0.4 0.4 0.2 15.1 3.2 1.2 

MEDEP Chapter 103 and 115, BPT] 

D. Visible emissions from the diesel generator set shall not exceed an opacity of 

30% on a 6-minute block average basis, except for no more than two 6-minute 

block averages in a 3-hour period. [MEDEP Chapter 101 ] 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

) 

) 

) 

12 

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Findings of Fact and Order 

Air Emission License 

(21) Whole Tree Chipper 

The whole tree chipper engine shall be limited to firing no greater than 20,500 

gallons per year of diesel fuel with a sulfur content of no greater than 0.05% 

sulfur by weight based on a twelve-month rolling total. 

[MEDEP Chapter 115, BPT] 

In order to demonstrate compliance with the fuel oil use restriction for the 

whole tree chipper engine, Lavalley shall maintain a fuel oil use log indicating 

the twelve-month rolling total fuel oil use in the whole tree chipper engine and 

including supplier certification indicating the #2 fuel oil sulfur content. 

[MEDEP Chapter 115, BPT] 

C. The whole tree chipper engine shall notexceed the following emission limits: 

Equipment PM 

lb/MMBtu 0.12 

Boiler #2 ib/hr 0.5 

MEDEP Chapter 103 and 115, BPT] 

PMlo SO2 NOx CO VOC 

0.5 0.2 14.6 3.9 1.6 

D. Visible emissions from the whole tree chipper engine shall not exceed an 

opacity of 30% on a 6-minute block average basis, except for no more than 

two 6-minute block averages in a 3-hour period. [MEDEP Chapter 101] 

(22) Wood Drying Kilns 

Ao Lavalley shall be restricted to a VOC emissions limit of 15.0 tons of VOC 

emissions per year from kiln drying operations based on a twelve-month 

rolling total. [MEDEP Chapter 115, BPT] 

To demonstrate compliance, Lavalley shall maintain a record of wood drying. 

The record shall include the quantity of wood dried in the kilns indicating 

drying dates and VOC emissions calculations based on the amount of wood 

dried and the emission factor of 2.26 pounds of VOC per 1000 BF. The VOC 

emissions record shall be maintained on a monthly and a 12-month rolling 

total basis. [MEDEP Chapter 115, BPT] 

(23) Fugitive Emissions 

Visible emissions from fugitive emission sources shall not exceed an opacity of 

20%, except for no more than 5-minutes in any 1-hour period. Compliance shall 

be determined by an aggregate of the individual fifteen-second opacity 

observations which exceed 20% in any 1-hour. [MEDEP Chapter 101 
Lavalley Lumber Company, LLC 

York County 

Sanford, Maine 

A-24-71-M-R 

) 

) 

) 

13 

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Findings of Fact and Order 

Air Emission License 

(24) Lavalley shall notify the Department within 48-hours and submit a report to the 

Department on a quarterly basis if a malfunction or breakdown in any component 

causes a violation of any emission standard (Title 38 MRSA §605-C). 

(25) Lavalley shall pay the annual air emission license fee within 30 days of March 31 

of each year. Pursuant to 38 MRSA 353-A, failure to pay this annual fee in the 

stated timeframe is sufficient grounds for the revocation of the license under 38 

MRSA 341-D, Subsection 3. 

DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

BY: 

2004. 

DAWN R. GALLAGHER, COMMISSIONER 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

The term of this Order shall be for five (5) years from the signature above. 

Date of initial receipt Of application: January 2 L 2004 

Date of application acceptance: January 28• 2004 

Date filed with the Board of Environmental Protection: 

This Order prepared by, Peter G. Carleton, Bureau of Air Quality 
Maine Woods Company, LLC 

Aroostook County 

Portage, Maine 

A-736-71-B-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

After review of the air emissions license renewal application, staff investigation reports 

and other documents in the applicants file in the Bureau of Air Quality, pursuant to 38 

M.R.S.A., Section 344' and Section 590, the Department finds the following facts: 

I. REGISTRATION 

A. Introduction 

Maine Woods .Company, LLC (Maine Woods) of Portage, Maine has applied to 

renew their air emission license, permitting the operation of emission sources 

associated with their hardwood sawmill and lumber drying facility. 

The previous license failed to address the kilns located at the facility. The kilns 

have been included in this license. EPA's AP-42 factors for NOx emissions from 

wood fired boilers were updated in July 2001. The updated factors were used for 

calculations in this license. 

B. Emission Equipment 

The following equipment is addressed in this license: 

Fuel Burning Equipment 

Equipment 

Furnace 

Dr,,cin• Kilns 

Maximum 

Capaci .ty 

28.8 MMBtu/hr 

3.5 MMBtu/hr 

10,400 MBF 

Fuel Type, 

% sulfur 

wood 

#2 oil, 0.5% 

Maximum 

Firing Rate 

3.2 ton/hr* 

25 gal/hr 

Ctrl Stack 

Eqpmnt # 

dual multicyclone 1 

none 2 

none 

*based on wood with a moisture content of 50%, Higher Heating Value 4500 Btu/lb 

C. Application Classification 

The application for Maine Woods does not include the licensing of increased 

emissions or the installation of new or modified equipment, therefore the license 

is considered to be a renewal of current licensed emissions units only. 
Maine Woods Company, LLC 

Aroostook County 

Portage, Maine 

A-736-71-B-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

II. BEST PRACTICAL TREATMENT (BPT) 

Introduction 

In order to receive a license the applicant must control emissions from each unit to 

a level considered by the Department to represent best practical treatment (BPT), 

as defined in Chapter 100 of the Bureau of Air Quality regulations. Separate 

control requirement categories exist for new and existing equipment as well as for 

those sources located in designated non-attainment areas. Descriptions of the 

applicable requirements are provided below under the appropriate headings. 

Before proceeding with the control requirements for each unit a general process 

description is provided to identify where the equipment fits into the process. 

Process Description 

Maine Woods manufactures green and dried hardwood lumber. 

Hardwood logs are delivered to the pile down area by trucks. The logs are 

accepted in precut and tree length form. Tree length material is slashed off-site 

and stored. From the pile down area, logs are transferred by truck to the mill 

infeed deck. Once debarked, the logs are sawed into lumber. 

Slabs and edgings are chipped. After screening to remove fines and dust, the 

chips are mechanically conveyed to concrete storage bins. From there the chips 

are conveyed to container trucks. The station is equipped with a railcar cover to 

minimize fugitive emissions during loading. 

Green lumber exits the sawmill as strapped bundles ready for shipment or as 

stickered bundles. The latter are transferred to the covered infeed carriages of the 

dry kilns using mobile lumber lifts. There are a series of six side-by-side steam 

heated, track style lumber dry kilns. From the dry kilns, the dry lumber is 

strapped for shipment. 

Bark and sawdust generated by the sawmill is burned in the boiler. Excess wood 

waste is sold to off-site markets. 

Boiler #1 

Boiler #1 fires green hardwood sawdust and hogged bark with an approximate wet 

basis moisture content of 50%. The boiler has a maximum capacity of 28.8 

MMBtu/hr, and was manufactured in 1998. It is therefore subject to EPA New 

Source Performance Standards (NSPS) Subpart Dc, for boilers with heat inputs 

between 10 MMBtu/hr and 100 MMBm/hr, manufactured after June 9, 1989. 

Boiler #1 is not subject to the standards for sulfur dioxide (section 60.42c) or 

particulate matter (section 60.43c) because the boiler fires wood and has a 

capacity of less than 30 MMBtu/hr. 
Maine Woods Company, LLC 

Aroostook County 

Portage, Maine 

A-736-71-B-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Emissions from Boiler #1 are vented to a multiclone to control particulate matter 

(PM). Remaining pollutants are minimized through good combustion practices. 

The following is a summary of BPT for Boiler #1: 

1. Continued use of a multiclone and continued good combustion practices. 

2. PM emission limits calculated based on the maximum fuel input, ash and 

carbon carryover, and the efficiency of the multiclone. The PM10 emission 

limit is based on AP-42 factors in which 61% of the emitted particulate matter 

was less than 10 microns in aerodynamic diameter. These PM limits meet the 

requirements of Chapter 103 of the Department's regulations. 

3. SO2, NOx and VOC emission limits are based on EPA's AP-42 factors, dated 

7/01 for wood fired boilers. 

4. CO emissions are calculated based on performance data from the 

manufacturer. 

5. Visible emissions from Boiler #1 shall not exceed 20%, except for one six 

minute period per hour of not more than 27% opacity. 

Co Furnace 

Maine Woods operates a 3.5 MMBtu/hr boiler in 'the garage/office building 

located on site. The Furnace fires #2 fuel oil, and is not subject to NSPS. 

BPT for the Furnace is the following: 

1. The firing of#2 fuel o{1 with asulfur content not to exceed 0.5% by weight. 

2. PM emission limits are regulated by MEDEP Chapter 103. PM•0 emission 

limits are based on the PM limits 

3. NOx, CO and VOC emission limits are based on EPA's AP-42 data dated 

9/98 for boilers firing fuel oil. 

4. Visible emissions from the Furnace's stack shall not exceed 20% opacity on a 

6 minute block average. 

Wood Drying Kilns 

Maine Woods operates six side-by-side steam heated, track style lumber dry kilns. 

Maximum capacity in the kilns is limited to 11,400,000 board feet. VOC 

emissions released during the wood drying process have been estimated using data 

from studies conducted by the National Council of the Paper Industry for Air and 

Stream Improvement (NCASI) and the University of Maine. No data exists for 

the species in consideration in Maine Woods' kilns, therefore an estimate of VOC 

emissions has been made using conservative softwood factors. Maine Woods 

shall maintain records of wood throughput in the kilns, on a 12-month rolling 

basis. 
Maine Woods Company, LLC 

Aroostook County 

Portage, Maine 

A-736-71-B-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

Fugitive Particulate Emissions 

Fugitive particulate matter may potentially be emitted in the wood waste transfer 

and collections system, including the transfer of wood chips to railcars. Potential 

sources of fugitive PM emissions also include material stockpiles and unpaved 

roadways, and ash handling. Maine Woods shall maintain all potential fugitive 

particulate matter sources to prevent visible emissions, in excess of 10% opacity 

on a six minute block average basis for more than one (1) six (6) minute block 

average in a 1- hour period, 

Facili _ty Emissions 

Facility emissions were based on continuous operation of boiler #1 and the heater 

unit. Maine Woods has the following emissions, based on a 12 month rolling 

total: 

Total Annual Emissions 

(used to calculate the annual license fee) 

Pollutant 

PM 

PM10 

S02 

NOx 

Boiler #1 

(tons) 

27.75 

15.14 

3.15 

27.75 

Furnace 

(tons) 

1.84 

1.84 

7.72 

5.37 

Drying Kilns 

(tons) 

Total 

Tons/year 

29.59 

16.98 

10.87 

CO 41.00 0.55 41.55 

VOC 4.79 0.04 18.92 23.75 

33.12 

III. AMBIENT AIR QUALITY ANALYSIS 

According to the Maine Regulations Chapter 115, the level of air quality analyses 

required for a renewal source shall be determined on a case-by case basis. Based on 

the total facility emissions, Maine Woods is below the emiss{ons level required for 

modeling and monitoring. 

ORDER 

Based on the above Findings and subject to conditions listed below, the Department 

concludes that the emissions from this source: 

will receive Best Practical Treatment, 

will not violate applicable emission standards, 

will not violate applicable ambient air quality standards in conjunction 

with emissions from other sources. 

The Department hereby grants air emission license A-736-71-B-R, subject to the 

following conditions: 
Maine Woods Company, LLC 

Aroostook County 

Portage, Maine 

A-736-71-B-R 

) 

) 

) 

5 

Departmental 

Findings of Fact and Order 

Air Emission License 

STANDARD CONDITIONS 

(1) Employees and authorized representatives of the Department shall be allowed 

access to the licensee's premises during business hours, or any time during which 

any emissions Units are in operation, and at such other times as the Department 

deems necessary for the purpose of performing tests, collecting samples, 

conducting inspections, or examining and copying records relating to emissions. 

(2) The licensee shall acquire a new or amended air emission license prior to 

commencing construction of a modification, unless specifically provided for in 

Chapter 115. 

(3) Approval to construct shall become invalid if the source has not commenced 

construction within eighteen (18) months after receipt of such approval or if 

construction is discontinued for a period of eighteen (18) months or more. The 

Department may extend this time period upon a satisfactory showing that an 

extension is justified, but may condition such extension upon a review of either 

the control technology analysis or the ambient air quality standards analysis, or 

both. 

(4) The licensee shah establish and maintain a continuing program of best 

management practices for suppression of fugitive particulate matter during any 

period of construction, reconstruction, or operation which may result in fugitive dust, and shall submit a description of the program to the Department upon 

request. 

(5) The licensee shall pay the annual air emission license fee to the Department, 

calculated pursuant to Title 38 MRSA §353. 

(6) The license does not convey any property rights of any sort, or any exclusive 

privilege. 

(7) The licensee shall maintain and operate all emission units and air pollution control 

systems required by the air emission license in a manner consistent with good air 

pollution control practice for minimizing emissions. 

(8) The licensee shall maintain sufficient records, to accurately document compliance 

with emission standards and license conditions and shall maintain such records for 

a minimum of six (6) years. The records shall be submitted to the Department 

upon written request. 

(9) The licensee shall comply with all terms and conditions of the air emission 

license. The filing of an appeal by the licensee, the notification of planned 
Maine Woods Company, LLC 

Aroostook County 

Portage, Maine 

A-736-71-B-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

changes or anticipated noncompliance by the licensee, or the filing of an 

application by the licensee for the renewal of a license or amendment shall not 

stay any condition of the license. 

(10) The licensee may not use as a defense in an enforcement action that the 

disruption, cessation, or reduction of licensed operations would have been 

necessary in order to maintain compliance with the conditions of the air emission 

license. 

(11) In accordance with the Department's air emission compliance test protocol and 40 

CFR Part 60 or other method approved or required by the Department, the 

licensee shall: 

(i) perform stack testing to demonstrate compliance with the applicable 

emission standards under circumstances representative of the facility's 

normal process and operating conditions: 

ao 

bo 

within sixty (60) calendar days of receipt of a notification to test 

from the Department or EPA, if visible emissions, equipment 

operating parameters, staff inspection, air monitoring or other 

cause indicate to the Department that equipment may be operating 

out of compliance with emission standards or license conditions; or 

pursuant to any other requirement of this license to perform stack 

testing. 

(ii) install or make provisions to install test ports that meet the criteria of 40 

CFR Part 60, Appendix A, and test platforms, if necessary, and other 

accommodations necessary to allow emission testing; and 

(iii) submit a written report to the Department within thirty (30) days from date 

of test completion. 

(12) If the results of a stack test performed under circumstances representative of the 

facility's normal process and operating conditions indicate emissions in excess of 

the applicable standards, then: 

(i) within thirty (30) days following receipt of such test results, the licensee 

shall re-test the non-complying emission source under circumstances 

representative of the facility's normal process and operating conditions and 

in accordance with the Department's air emission compliance test protocol 

and 40 CFR Part 60 or other method approved or required by the 

Department; and 
Maine Woods Company, LLC 

Aroostook County 

Portage, Maine 

A-736-71-B-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(ii) the days of violation shall be presumed to include the date of stack test and 

each and every day of operation thereafter until compliance is 

demonstrated under normal and representative process and operating 

conditions, except to the extent that the facility can prove to the 

satisfaction of the Department that there were intervening days during 

which no violation occurred or that the violation was not continuing in 

nature; and 

(iii) the licensee may, upon the approval of the Department following the 

successful demonstration of compliance at alternative load conditions, 

operate under such alternative load conditions on an interim basis prior to 

a demonstration of compliance under normal and representative process 

and operating conditions. 

(13) Notwithstanding any other provision in the State Implementation Plan approved 

by the EPA or Section 114(a) of the CAA, any credible evidence may be used for 

the purpose of establishing whether a person has violated or is in violation of any 

statute, regulation, or Part 70 license requirement. 

(14) The licensee shall maintain records of malfunctions, failures, downtime, and any 

other similar change in operation of air pollution control systems or the emissions 

unit itself that would affect emissions and that is not consistent with the terms and 

conditions of the air emission license. The licensee shall notify the Department 

within two (2) days or the next state working day, whichever is later, of such 

occasions where such changes result in an increase of emissions. The licensee 

shall report all excess emissions in the units of the applicable emission limitation. 

(15) Upon written request of the Department, the licensee shall establish and maintain 

such records, make such reports, install, use and maintain such monitoring 

equipment, sample such emissions (in accordance with such methods, at such 

locations, at such intervals, and in such manner as the Department shall 

prescribe), and provide other information as the Department may reasonably 

require to determine the licensee's compliance status. 

SPECIFIC CONDITIONS 

(16) Boiler #1 

A. Maine Woods shall fire wood fuel in Boiler #1. Maine Woods may also fire 

sawdust, oily sawdust, and oily rags. 
Maine Woods Company, LLC 

Aroostook County 

Portage, Maine 

A-736-71-B-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

B. The following limits shall not be exceeded by Boiler #1: 

Boiler #1 Emission Limits 

Pollutant 

PM 

PM10 

SO z 

NO x 

CO 

VOC 

lb/MMBtu 

0.22 

lb/hr 

6.34 

3.46 

0.72 

6.34 

1.09 

C. Maine Woods shall operate and maintain a multiclone on the emissions from 

Boiler #1. Maine Woods shall keep a maintenance log of all failures and 

maintenance, routine or otherwise, on the multiclone. 

D. Boiler #1 is subject to 40 CFR 60 Subpart Dc, New Source Performance 

Standards for boilers with heat inputs between 10 MMBtu/hr and 100 

MMBtu/hr and manufactured after June 9, 1989. Maine Woods shall comply 

with all applicable monitoring, record keeping and reporting requirements of 

Subparts A and Dc. 

E. Visible emissions from Boiler #1 shall not exceed 20%, except for one six 

minute period per hour of not more than 27% opacity. 

(17) Furnace 

A. Maine Woods shall fire #2 fuel oil with a sulfur content not to exceed 0.5% by 

weight in the Furnace. Compliance shall be demonstrated through fuel 

delivery receipts showing the sulfur content of the fuel oil. 

B. The Furnace shall not exceed the following limits: 

Furnace Emission Limits 

Pollutant lb/MMBtu lb/hr 

PM 0.12 0.42 

PM10 0.42 

SOz 

NOx 

CO 

VOC 

1.76 

1.23 

0.13 

0.01 

C. Visible emissions from the Furnace shall not exceed 20% opacity on a 6 

minute block average. 
Maine Woods Company, LLC 

Aroostook County 

Portage, Maine 

A-736-71-B-R 

Departmental 

Findings of Fact and Order 

Air Emission License 

(18) Drying Kilns 

Yearly throughput is limited to 11,400,000 board feet per year based on a 12- 

month rolling total. Compliance shall be demonstrated through kiln loading 

records. 

(19) From fugitive particulate matter sources, Maine Woods shall not exceed 10% 

opacity on a six minute block average basis for more than one (1) six (6) minute 

block average in a 1 hour period. Potential fugitive particulate matter sources 

include the wood waste transfer and collections 'system (including the transfer of 

wood chips to railcars), material stockpiles and unpaved, roadways, and ash 

handling. 

(20) A copy of this Order shall be kept on site and the operator(s) shall be familiar with 

the terms and conditions of the Order. 

(21) Maine Woods Company shall pay the annual air emission license fee within 30 

days of May 31 of each year. Pursuant to 38 MRSA §353-A, failure to pay this 

annual fee in the stated timeframe is sufficient grounds for revocation of the 

license under 38 MRSA §341-D, subsection 3. 

(22) The term of this order shall be for five (5) years from the signature date below. 

DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

2003: 

BY: 

DAWN R. GALLAGHER, COMMISSIONER 

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES 

Date of initial receipt of application: 

Date of application acceptance: 

March 18, 2003 

March 26, 2003 

Date filed with Board of Environmental Protection: 

This order prepared by Rachel E. Pilling, Bureau of Air Quality