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} 151524

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 #

12B3

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 #V2fugitiveColumbia 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) )))8

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 13.1Columbia 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) )))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) )))11

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 PMPM•0SO2NOx Emissions

in Tons/Year

COVOCHAPs 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) )))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

5172.859 573.463 0.90 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

5172.76iColumbia Forest Products Aroostook County Presque Isle, Maine A-353-71-H-R (SM) )))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 StackStack 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

1.051.058.898.8937.3537.35
0.74 3.50

415.93[

18.58Columbia Forest Products Aroostook County Presque Isle, Maine A-353-71-H-R (SM) )))14

Departmental Findings of Fact and Order Air Emission

License

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

1.721.720.711.30

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

PollutantSO2 Averaging Period

MaxImpactQtg/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

1Class II Significanc e Level(•t•/m 3)25Columbia Forest Products Aroostook County Presque Isle, Maine A-353-71-H-R (SM) )))15

Departmental Findings of Fact and Order Air Emission

License

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

PollutantSO2

PMlo
NO2CO Averaging Period3-hour 24-hour Annual 24-hour Annual Annual1-hour8-hour

MaxImpact.(•tg/m 3) 97.4127.068.6625.978.3110.88142.2599.57 Receptor UTM E(km)572.571 572.571572.57! 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)204.22204.22204.22201.17201.17 201.17201.17

Class II Significance Level(btg/m 3)255

112000 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 ElizabethColumbia Forest Products Aroostook County Presque Isle, Maine A-353-71-H-R (SM) )))16

Departmental Findings of Fact and Order Air Emission

License
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) MaxTotalImpact(gg/m 3) MAAQS(gg/m •)

24 282.73

1150 13 190.12

230 5 57 32 47.11135.4924.2835.09

Increment 1011

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. 1504O100Columbia Forest Produ cts Aroostook County Presque Isle, Maine A-353-71-H-R (SM) )))17

Departmental Findings of Fact and Order Air Emission

License

Table III-7: Increment

Consumption

in Class II Areas from CFP Alone

PollutantPM1o
NO2 Averaging Period 24-hour Annual AnnualKey:

* 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)161.54179.83161,54

Class II Increment

301725

Table III-8: Combined

Source Class II Increment

Consumption

PollutantPMt0
NO2 Averaging Period 24-hour Annual

MaxImpact(p•/m •) 12.10"0.55* 573.371 17.84" AnnualKey: 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)161.54179.83161.54

Class II Increment (l•glm •)3017

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) )))18

Departmental 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) )))19

Departmental 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; andColumbia Forest Products Aroostook County Presque Isle, Maine A-353-71-H-R (SM) )))20

Departmental 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) )))22

Departmental Findings of Fact and Order Air Emission

License

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

101Columbia Forest Products Aroostook County Presque Isle, Maine A-353-71-H-R (SM) )))23

Departmental Findings of Fact and Order Air Emission

License
(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, BPTCO 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) )))24

Departmental 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 4.413.1
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) )))25

Departmental Findings of Fact and Order Air Emission

License

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;

or2) 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) )))26

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 QualitySonoco 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 BoilerBoiler #2 Emergency Generator*

Maximum Capacity (MMBtu/hr) 27201.22
*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

23

Process Equipment
Equipment Spray Paint Booths KilnsFinger Joining Operation

Regulated Pollutant VOC & PM VOCVOC

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.
KilnsSonoco 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

PMPMlo Tons/Year

53.753.7 SO2 4.2 NOx 22.4 COVOC 82.616.8

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 circumstancesSonoco 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
0.204.00 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;

or2) 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/hrGeneva 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:

PollutantPMPM10SO2 Max. Future License
24.424.43.1

Sia. Level100100100 NOx 22.95

100 COVOC 76.549.9

10050

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 increasesGeneva 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

PollutantPMPM•o'SO2NOxCO Tons/Year

2550100250

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 forGeneva 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]:

PM0b/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 requirementsGeneva 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;

or2) 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 #

23

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.
KilnsHancock 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

PM1.714.2

15.9

PM•01.714.2

15;9

SO24.91.2

6.1

NOx4.910.4

15.3

CO0.528.428.,9

VOC0.10.822.623.5

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

PMPM10

Tons/Year
2525 SO2 50 NOxCO 100250
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 CumberlandCountyCasco, 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]
KilnsA. 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;

or2) 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/hrAndover 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 toAndover 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 fromAndover 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

15.80.1

15.80.1

1.30.02

25,81.5

31.50.3

0.90.1 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 100250 CO

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/MMBtu0.2

Ib/hr2.9

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 0.20Andover 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 PMPM10 0.40.4 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;

or2) 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)

20.316.5

Maximum Firing Rate (•al/hr)

135110

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/hrlb/MMBtu lb/hr

PM0.122.40.122.0

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 #

12

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 UnitsBoilers Emergency Unit #1 Emergency Unit #2 Total

Total Allowable

Annual Emission

for the Facility (used to'calculate

the annual license fee) Tons/yr

2.800.09
0.18
3.07 2.800:09
0.18
3.07

SO24.940.26
0.52

5•72

2.003.23
4.68

9.91

 ̧CO0.500.70
1.24

2.44

VOC0.060.26
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

PMPM•oS02NOxCO

Tons/Year

2550100250

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; andFranklin 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/hrlb/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

0.350.12
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 QualityFrontier 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 PollutantPMVOC, 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 paperFrontier 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
0.634.4

35.0

TotalHAP

9.9
9,9Frontier 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

PMPM10SO2NOxCO

Tons/Year

25 ̧2550100250
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 whichFrontier 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 aFrontier 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, BPTFrontier 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] CoFrontier 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;

or2) 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} 4.72.41.51.5

Maximum Firing Rate (•al/hr)33.517.410.410.4

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:• 3.5 2.1 Boilers (total)

0.6

0.6 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 DepartmentGrand 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, BACTGrand 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

PM0b/hr)

0.380.190.120.12

PM10(lb/hr)

0.380.i90.120.12

SO2(lb/hr)

2.361.220.730,73

NOI(lb/hr)

1.410.730.440.44

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

3Mid 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
0.06Mid 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

SO2.0.0020.04

NOx

CO 0.2 0.2 0.4 0.05

VOC0,010•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

0.01Mid 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•4.24.2

Firing Rate (•al/hr)14.529.029.0 uipment

Fuel Type, % sulfur #2, #4, 0:5% #2, #4, 0.5% #2, #4, 0.5%

Stack #

111
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 TPYTotal

Licensed

Annual Emissions

for the Facility Tons/year used to calculate

the annual license fee' PM1.310.070.071.45 PM101.31.

1.45

8025.600.030.035.66

NOx3.812.262.58.57

.CO0.380.490.541.41

VOC0.030.180.200.41
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 anBlue 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 licenseeBlue 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)

0.260.51•0.51'

PMlo(lb/hr)

0.260.51.0.51

S02(lb/hr)

1.092.172.17

NOx(lb/hr)

0:741.471.47

CO(lb/hr)

VOC.(lb/hr)

0.150.150.08 0.010.010.01Blue 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

PM0b/hr).,

0.260.510.51

PM•o(lb/hr)

0.260.510.51

S02(lb/hr)

1.062.172.17

NOx0b/hr)

0.631.261.26

CO_(lb/hr)

0.080.150.15

VOC(lb/hr)

0.010.010.01
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)

0.250.28

PMlo(lb/hr)0,250.28

SO2(lb/hr)

0.110:12

NOx(Ib/hr)

9.1.10.0

CO(Ib/hr)

1.952.16

VOC(lb/hr)

0•720.80

(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) 8.40.18

Maximum Firing .Rate (•aFhr)60.01.81.8

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 Rate60,000 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 21.421.4 PM10

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 41.8 0.7

1.10.1

Total21.621.614.615.521.142.6

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;

andNortheastern 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 0.121.0 1.0

2.6SO2

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 QualityLovell 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) 5.51.25.5

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 19981993 Diesel, 0.05% Diesel, 0.05%

199319821984

Stack #
#1#1#1#4#5

Process Equipment Equipment Kiln #1 Production

Rate 4.5 MMBF/yr

Pollution

Control Equipment

noneLovell 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 1.3 PMPM10 10.2

1.3015 NOx 0.97.520.51.3 COVOC

34.0

Total11.511.51.441.529..57.5Lovell 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; andLovell 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 .0.32.6 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 0.120.65 0.65

0.3 0.4 0.4 0.06 0.120.65 0.65

0.3 NOx

CO
17.4 4.6 5.4 1.2

17.4 4.6 VOC

0.50.4

0.5Lovell 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

101Loveil 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 QualityHancock 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

noneHancock 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•018.2

18.2

S021.4

1.4

NOx12.1

12.1

CO33.1

33.1

VOC0.932.833.7

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 whichHancock 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 0.21Hancock 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

101Hancock 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;

or2) 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 GasifierEmergency 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

EoD. 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

10.53.30.60.1

14.5

PM•010.53.30.60.1

14.5

SO237.00.10.10.1

37.3

NOx38.94.00.65.9

19.4

CO3.88.02.71.3

15.8

VOC0.20.30.1

33.935.0Hancock 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

PMPM10SO2NOxCO

Tons/Year

252550100250
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

101Hancock 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

eMlo0b/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;

or2) 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 NoneNoneCycloneCycloneCyclone

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 yearKatahdin 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 SO2NOx 1.5513.6837.323.66 COVOC

1001001005O

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

PM15.55

15.55

PM1015.55

15.55

SO21.55

1.55

NOx13.68

13.68

CO37.32

37.32

VOC1.060.62.0

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

Departmental Findings of Fact and Order Air Emission

License

(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;

andKatahdin Forest Products Aroostook County Oakfield, Maine A-939-71-A-N 8

Departmental Findings of Fact and Order Air Emission

License

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 contentsKatahdin Forest Products Aroostook County Oakfield, Maine A-939-71-A-N 10

Departmental Findings of Fact and Order Air Emission

License

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 againstKatahdin Forest Products Aroostook County Oakfield, Maine A-939-71-A-N 11

Departmental Findings of Fact and Order Air Emission

License

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;

or2) 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

updateKatahdin Forest Products Aroostook County Oakfield, Maine A-939-71-A-N 12

Departmental Fin dings of Fact and Order Air Emission

License

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) 33.514.6

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)32.6Lavalley Lumber

Company,

LLC York County Sanford, Maine A-24-71-M-R )))2

Departmental Findings of Fact and Order Air Emission

License

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 )))3

Departmental Findings of Fact and Order Air Emission

License 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 )))4

Departmental Findings of Fact and Order Air Emission

License

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 )))5

Departmental Findings of Fact and Order Air Emission

License

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 tonLavalley Lumber

Company,

LLC York County Sanford, Maine A-24-71-M-R )))6

Departmental Findings of Fact and Order Air Emission

License

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 PMPM10SO2NOxCOVOC Tons/Year 61.661.621.192.082.328.8

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) )))7

Departmental 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 )))8

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. (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; andLavalley 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 #1Lavalley 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

Departmental 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

Departmental 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

101Lavalley Lumber

Company,

LLC York County Sanford, Maine A-24-71-M-R )))13

Departmental 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 QualityMaine 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

MaximumCapaci .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

PMPM10S02NOx Boiler #1(tons)27.7515.143.1527.75

Furnace(tons)1.841.847.725.37

Drying Kilns (tons)

TotalTons/year 29.5916.9810.87

CO 41.00

0.55 41.55 VOC 4.79

0.04

18.92

23.7533.12

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 plannedMaine 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; andMaine 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 PMPM10SO zNO xCOVOC

lb/MMBtu 0.22 lb/hr6.343.460.726.34

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

0.420.42 PM10SOzNOxCOVOC 1.761.230.130.01

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