Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I

After review of the Initial Part 70 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

FACILITY Dragon Products Company, Inc. (Dragon) LICENSE NUMBER A-326-70-A-I LICENSE TYPE Initial Part 70 License NAIC CODES 32731 NATURE OF BUSINESS Cement Manufacturing FACILITY LOCATION Thomaston, Maine DATE OF LICENSE ISSUANCE December 31, 2003 LICENSE EXPIRATION DATE December 31, 2008

B. Emission Equipment Dragon is authorized to operate the following air emission units:

Combustion Equipment

Equipment Nominal Capacity (MMBtu/hr) 1 Nominal Firing Rate 1 Fuel Type, % Sulfur 2 Stack #

New Kiln (U804) 440.0 14.35 tph Coal, 1.3% 14.35 tph Petroleum Coke, 4.5% 30.0 gpm #2 Fuel Oil, 0.5% 28.0 gpm. #4 Fuel Oil, 0.5% 30.0 gpm Specification Waste Oil and non-Specification Waste Oil 20% of total fuel usage Whole Tire or Chips 1Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 2

Combustion Equipment (Continued)

Equipment Nominal Capacity (MMBtu/hr) 1 Nominal Firing Rate 1 Fuel Type, % Sulfur 2 Stack #

12.0 tph Coal 12.0 tph Petroleum Coke 30.0 gpm #2 Fuel Oil, 0.5%, #4 Fuel Oil 0.5% 30.0 gpm Specification Waste Oil and non-Specification Waste Oil Existing Kiln 306.0

20% of total fuel usage Whole Tire or Chips 1

Insignificant Fuel Burning Equipment

Equipment Nominal Capacity (MMBtu/hr) 1 Fuel Type, % Sulfur 2 Stack #

Machine Shop Heater < 3.0 #2 Fuel Oil, 0.35% A.V. Core Building Heater < 3.0 #2 Fuel Oil, 0.35% A.V. Emergency Generator < 3.0 Diesel Fuel, 0.05% n/a Quarry Discharge Pumps (2) < 3.0 Diesel Fuel, 0.05% n/a

1 Equipment with a listed capacity or firing rate within the Finding of Fact are for identification purposes only. Capacities determined to be license limits are noted as such in the Order section.

2 Sulfur content listed in the Finding of Fact is for general information only. Where sulfur contents are intended to be a license limit it is listed in the Order section of the license.

General Process Equipment

Emission Unit ID Emission Unit Name

U886 Alkali (Preheater) Bypass(vented via Stack #1) U053 Clinker Cooler U766 Pregrinder Vent U203 Rock Silo #1 U445 Weighfeeders from Silos 1, 2, and 4 U447 Weighfeeders from Silos 5 and 6 U460 Raw Mill Fugitive SourcesDragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 3

General Process Equipment (Continued)

Emission Unit ID Emission Unit Name

U506 Raw Mill Fugitive U511 Below Raw Mill Cyclones U767 Pregrinder Product Transport U785 FM #1 Mill Feed U828 Kiln Feed Bin U830 Homogenizing Silo Top

C. Application Classification The application for Dragon does not include the licensing of increased emissions or the installation of new or modified equipment, therefore the license is considered to be an Initial Part 70 License issued under Chapter 140 for a Part 70

source.

II. EMISSION UNIT DESCRIPTION

A. General Process Description

Dragon operates a cement manufacturing facility in Thomaston. The facility, built in 1971, is a wet process cement kiln. Dragon has been licensed to modernize the facility by converting to the more efficient dry cement manufacturing process. The modernization project was authorized by air license A-326-71-U-A/R in accordance with DEP Chapter 115.

Due to technology improvements that are part of the modernization project, the project does not result in a significant net emission increase. DEP found that federal New Source Review (i.e. PSD and Non attainment NSR) permits were not required for this project. The PSD avoidance and minor modification provisions of air license A-326-71-U-A/R are incorporated into this Part 70 license. As part of the review for issuance of license A-326-71-U-A/R, DEP determined that the proposed new and modified emission units, including the new cement kiln, will meet Best Available Control Technology (BACT) requirements. As part of Dragon’s application for the modernization project , refined modeling was performed to show that emissions from Dragon’s new plant configuration, in conjunction with other sources, would not cause or contribute to violations of Maine’s Ambient Air Quality Standards (MAAQS) for sulfur dioxide (SO 2 ), Particulate Matter (PM 10 ), Nitrogen Dioxide (NO 2 ) and Carbon Monoxide (CO).

The modernization project will convert the existing wet process cement kiln to a dry process (preheater/precalciner type), convert the existing (wet) raw mill to a pregrinding finish cement mill, and improve other ancillary operations within theDragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 4

facility. The planned annual production rate of the new facility is approximately 766,500 tons of clinker. The new dry cement manufacturing process can be divided into three main sections: 1) kiln feed preparation, 2) clinker production, and 3) finish cement operations. 1) Kiln Feed Preparation The basic ingredients of cement include oxides of calcium, silica, aluminum, and iron. Due to the requirement for large quantities of calcium oxide (CaO), portland cement plants are generally located near a source of the calcareous material (limestone, in the case of Dragon). The limestone for Dragon’s manufacturing process is mined from quarries located at the site. Raw limestone is transported from the quarry to a crusher and then to roller mills which grind the material to the desired fineness. The ground material is collected and fed to a blending system to provide the kiln with raw feed. 2) Clinker Production Clinker production involves high temperature processing in the rotary kiln, where necessary chemical reactions take place to produce a product referred to as “clinker”. The kiln is a counter-current heating device, meaning material fed into the cool upper end is drawn slowly by gravity to the hot discharge end. The burners at the discharge end of the kiln produce a current of hot gases that heat the clinker, the calcined material and raw materials in succession as the hot gases pass upward toward the feed end. In the new kiln, the clinker formation process occurs in a series of stages that correlate with the temperature of the raw materials and in a unit called a calciner or precalciner. These stages and precalciner are located in a structure called a preheater tower. In the preheater, uncombined water evaporates from raw materials. Material temperature increases to the point where calcination begins. As calcination occurs, carbon dioxide is liberated from the carbonate component. Sintering of the oxides occurs in the burning zone of the kiln. The sintering (or clinkering) reactions chemically combine calcines material with silica, alumina, and iron to form tricalium silicate (Ca 3 SiO 5 ), dicalcium silicate (Ca 2 SiO 4 ), tricalcium aluminate (Ca 3 Al 2 O 6 ), and tetracalcium alumino-ferrite (Ca 4 AlFeO 7 ). Following the sintering reactions, clinker is quickly cooled by contact with ambient air. Some heat transferred to the cooler air is recouped back into the process. 3) Finish Cement Operations The cooled clinker is stored prior to being sent to the finishing mills where it is combined with gypsum and other additives. The clinker and gypsum are ground to a fine, homogenous powder in a series of ball mills. The finished portland cement is then transferred to the cement storage silos prior to shipment off-site.Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 5

B. New Portland Cement Kiln System The new kiln has a nominal design heat input of 440 MMBtu/hr firing the following fuels:

1. A coal/coke blend of fuel, 2. #2-#4 fuel oil blend, 3. Specification and Non-Specification waste oil, and 4. Whole tires and tire chips. And may use the following raw materials:

1. Petroleum-contaminated soils, 2. Landfill leachate, 3. Petroleum-contaminated water, 4. Fly ash, 5. Kraft pulp mill green liquor dregs, 6. Lime mud, and lime wastes (PCC Grit) 7. Slaker grit, and 8. Foundry Sand. Dragon may also utilize alternate fuels and raw materials which meet the requirements of Condition 14(C) of this license. Particulate emissions in the exhaust from the kiln and alkali bypass are controlled by a fabric filter baghouse. The previously licensed NO x RACT requirements for Dragon’s existing wet process cement kiln shall not apply to the new kiln system. The new kiln system is subject to more stringent BACT requirements.

Streamlining 1. 40 CFR Part 63.1343 (MACT) and MEDEP Chapter 105 regulate particulate matter (PM) emission limits from the new cement kiln system. However, Best Available Control Technology (BACT) in license A-326-71-U-A/R and the MACT limit in 40 CFR Part 63.1343 are more stringent than Chapter 105 so that only the BACT and MACT limits identified in Condition 14(F) in the Order section of this license are applicable.

2. Chapter 101 is applicable for visible emissions. However, 40 CFR Part 63.1343 (MACT) is more stringent so that only the MACT limit identified in Condition 14(H) in the Order section of this license is applicable. During periods of kiln preheat and start up, condensation in the kiln exhaust causes false positive readings by the opacity monitor. For this reason, when the exhaust, as measured at the kiln ID fan, is less than 250 o F, monitored opacity readings greater than 20% as measured on a six (6) minute block average basis are not considered an excess emission.Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 6

3. 40 CFR Part 63.1350(c) and Chapter 117 require the use of Continuous Opacity Monitors (COM). However, Chapter 117 is at least as stringent as 40 CFR Part 63.1350(c) so that only the Chapter 117 requirement is identified in the Order section of this license.

4. 40 CFR Part 63.8 and Chapter 117 detail the sampling frequency of the CEM and COM. However, Chapter 117 is at least as stringent as 40 CFR Part 63.8 so that only the Chapter 117 requirement is identified in the Order section of this license

Periodic Monitoring Stack testing for dioxin/furans every 2.5 years.
One time initial stack test for VOC with the first dioxin/furan stack test. Daily records of fuel use including: gallons of #2 fuel oil, gallons of #4 fuel oil, fuel sulfur content, gallons of specification and/or non-specification waste oil, tons of tires/tire chips, tons of coal, tons of petroleum coke, tons of fly ash or any other alternative fuel used. Continuous Monitoring Documentation that the COM, SO 2 , CO, and NO x CEMs are continuously accurate, reliable and operated in accordance with Chapter 117, 40 CFR Part 51 Appendix P, and 40 CFR Part 60 Appendices B and F.

C. Existing Portland Cement Kiln System The existing kiln is rated with a nominal heat input of 306 MMBtu/hr and is authorized to use one or a combination of the following as fuel:
1. A coal/coke blend of fuel, 2. #2 fuel oil, 3. #4 fuel oil, 4. Specification and Non-Specification waste oil, and 5. Whole tires and tire chips. In addition to the basic raw materials used in the manufacture of clinker (sources of calcium, iron, silica, and alumina), Dragon may also use one or a combination of the following raw materials in the production of clinker:
1. Petroleum-contaminated soils, 2. Landfill leachate, 3. Petroleum-contaminated water, 4. Fly ash, 5. Kraft pulp mill green liquor dregs, 6. Lime mud, and lime wastes (PCC Grit) 7. Slaker grit, and 8. Foundry Sand.Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 7

Dragon may also utilize alternate fuels and raw materials which meet the requirements of Special Condition 14(C) of the license. Particulate emissions on the existing Kiln are controlled by a fabric filter baghouse referred to as the kiln baghouse

NO x RACT for the existing kiln was previously determined to be: improvements to the kiln’s chain hanging pattern, revisions to the clinker cooler, firing a blend of coal and petroleum coke as the primary fuel source, and low NO x burners. Streamlining 1. 40 CFR Part 63.1343 (MACT) and MEDEP Chapter 105 regulate particulate matter (PM) emission limits from the existing kiln system. However, Best Available Control Technology (BACT) and MACT are more stringent so that only the BACT and MACT limits identified in Condition 16(G) in the Order section of this license are applicable.

2. Chapter 101 is applicable for visible emissions. However, 40 CFR Part 63.1343 (MACT) is more stringent so that only the MACT limit identified in Condition 16(G) in the Order section of this license is applicable. During periods of kiln preheat and start up, condensation in the kiln exhaust causes false positive readings by the opacity monitor. For this reason, when the exhaust, as measured at the kiln ID fan, is less than 250 o F, monitored opacity readings greater than 20% as measured on a six (6) minute block average basis are not considered an excess emission.

3. 40 CFR Part 63.1350(c) and Chapter 117 require the use of Continuous Opacity Monitors (COM). However, Chapter 117 is at least as stringent at 40 CFR Part 63.1350(c) so that only the Chapter 117 requirement is identified in the Order section of this license.

4. CFR Part 63.8 and Chapter 117 detail the sampling frequency of the CEMs and COM. However, Chapter 117 is at least as stringent as 40 CFR Part 63.8 so that only the Chapter 117 requirement is identified in the Order section of this license. Periodic Monitoring Stack testing for dioxin/furans every 2.5 years. Daily records of fuel use including: gallons of #2 fuel oil, gallons of #4 fuel oil, fuel sulfur content, gallons of specification and/or non-specification waste oil, tons of tires/tire chips, tons of coal, tons of petroleum coke, tons of fly ash or other alternative fuel. Continuous Monitoring Documentation that the COM, SO 2 , and NO x CEMs are continuously accurate, reliable and operated in accordance with Chapter 117, 40 CFR Part 51 Appendix P, and 40 CFR Part 60 Appendices B and F.Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 8

D. Clinker Cooler Streamlining 1. 40 CFR Part 63.1345 and MEDEP Chapter 105 regulate particulate matter (PM) emission limits from the clinker cooler. However, the Best Available Control Technology (BACT) PM limit in license A-326-71-U-A/R is more stringent so that only the BACT limit identified in Condition 16(F) in the Order section of this license is applicable.

2. Chapter 101 is applicable for visible emissions. However, 40 CFR Part 63.1345 (MACT) is more stringent so that only the MACT limit identified in Condition 16(F) in the Order section of this license is applicable.

3. 40 CFR Part 63.1350(d) and Chapter 117 require the use of Continuous Opacity Monitors (COM). However, Chapter 117 is at least as stringent as 40 CFR Part 63.1350(d) so that only the Chapter 117 requirement is identified in the Order section of this license.

4. 40 CFR Part 63.8 and Chapter 117 detail the sampling frequency of the COM. However, Chapter 117 is at least as stringent as 40 CFR Part 63.8 so that only the Chapter 117 requirement is identified in the Order section of this license.

Periodic Monitoring Stack testing for particulate matter emissions from the clinker cooler every other year. Continuous Monitoring Documentation that the COM is continuously accurate, reliable and operated in accordance with Chapter 117, 40 CFR Part 51 Appendix P, and 40 CFR Part 60 Appendices B and F.

E. Finish Mills Streamlining Chapter 101 is applicable for visible emissions. However, 40 CFR Part 63.1347 (MACT) is more stringent so that only the MACT requirement is identified in the Order section of this license. Periodic Monitoring Daily visible emissions observation on mill sweep and separator particulate matter control devices in accordance with 40 CFR Part 63.1350(e). Periodic Method 9 performance tests as required by 40 CFR 63 Subpart LLL.Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 9

F. Other Portland Cement MACT Sources Streamlining Chapter 101 is applicable for visible emissions. However, 40 CFR Part 63.1348 is more stringent so that only the 40 CFR Part 63.1347 requirement is identified in the Order section of this license.

Periodic Monitoring Monthly visible emissions observations in accordance with an operations and maintenance plan in accordance with 40 CFR Part 63.1350(j).

Periodic Method 9 performance tests as required by 40 CFR 63 Subpart LLL.

G. Miscellaneous Insignificant Emissions Units Miscellaneous emission units include internal combustion engines less than 3.0 MMBtu/hr firing 0.05% sulfur or less fuel oil as well as heaters and boilers less than 3.0 MMBtu/hr firing 0.35% sulfur or less fuel oil. These are noted for informational purposes only.

H. Stockpile and Roadway Fugitive Emissions Fugitive particulate matter sources at Dragon includes material stockpiles and roadways. Periodic Monitoring Based on best management practices, fugitive emission sources should not exceed the opacity limits. Therefore, periodic monitoring for opacity in the form of visible emission is not required. However, neither the EPA nor the DEP is precluded from performing its own testing and may take enforcement action for any violations discovered.

I. Annual Emission Dragon has the following annual emissions, based on 8,760 hours of kiln, heater and quarry pump operation and 500 hours of emergency generator operation: (12 month rolling total)
Total Annual Emissions for Combustion Sources and

Fuel Burning Equipment With Existing Wet Kiln (used to calculate the annual license fee)

PM PM 10 SO 2 NO x * CO VOC Existing Kiln and Cooler 165.13 165.13 451.00 2249.00 843.20 31.50

*NO x as measured as NO 2Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 10

Total Annual Emissions for Combustion Sources and Fuel Burning Equipment With New Dry Kiln (used to calculate the annual license fee)

PM PM 10 SO 2 NO x * CO VOC New Kiln 41.17 41.17 306.60 1533.00 843.20 57.70 New Cooler 40.08 40.08 -- -- -- --

Total TPY 81.3 81.3 306.6 1533.00 843.2 57.7

*NO x as measured as NO 2 III. AIR QUALITY ANALYSIS

As part of Dragon’s application for the modernization of the cement plant, refined Modeling was performed to show that emissions from Dragon, in conjunction with other sources, would not cause or contribute to violations of Maine’s Ambient Air Quality Standards (MAAQS) for sulfur dioxide (SO 2 ), Particulate Matter (PM 10 ), Nitrogen Dioxide (NO 2 ) and Carbon Monoxide (CO).

It was determined by MEDEP-BAQ that Dragon is not increment consuming. Therefore, neither Class I nor Class II increment analysis was performed. Dragon is a major source that was permitted for a minor modification in license A-326-71-U-A/R. Since, the modernization project is a minor modification, MEDEP-BAQ determined that an evaluation of Class I increment, visibility and deposition is not required.

The modeling is summarized in license A-326-71-U-A/R. Based on the results of the model, MEDEP-BAQ determined that the Dragon facility (as modernized) will not cause or contribute to violations of any SO 2 , PM 10 , NO 2 , and CO averaging period MAAQS or Class I or Class II increments.

ORDER Based on the above Findings and subject to conditions listed below, the Department concludes that emissions from this sources:

• will receive Best Practical Treatment;

• will not violate applicable emissions standards

• will not violate applicable ambient air quality standards in conjunction with emissions from other sources.

The Department hereby grants the Part 70 License A-326-70-A-I pursuant to MEDEP Chapter 140 and the preconstruction permitting requirements of MEDEP Chapter 115 and subject to the standard and special conditions below.

All federally enforceable and State-only enforceable conditions in existing air licenses previously issued to Dragon pursuant to the Department’s preconstruction permitting requirements in Chapters 108 or 115 have been incorporated into this Part 70 license,Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 11

except for such conditions that MEDEP has determined are obsolete, extraneous or otherwise environmentally insignificant, as explained in the findings of fact accompanying this permit. As such, the conditions in this license supercede all previously issued air license conditions.

Federally enforceable conditions in this Part 70 license must be changed pursuant to the applicable requirements in Chapter 115 for making such changes and pursuant to the applicable requirements in Chapter 140.

For each standard and special condition which is state enforceable only, state-only enforceability is designated with the following statement: Enforceable by State-only

.

Standard Statements

(1) 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;

(2) The Part 70 license does not convey any property rights of any sort, or any exclusive privilege;

(3) All terms and conditions are enforceable by EPA and citizens under the CAA unless specifically designated as state enforceable.

(4) 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;

(5) 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.

(6) Compliance with the conditions of this Part 70 license shall be deemed compliance with any Applicable requirement as of the date of license issuance and is deemed a permit shield, provided that:Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 12

a. Such Applicable and state requirements are included and are specifically identified in the Part 70 license, except where the Part 70 license term or condition is specifically identified as not having a permit shield; or

b. The Department, in acting on the Part 70 license application or revision, determines in writing that other requirements specifically identified are not applicable to the source, and the Part 70 license includes the determination or a concise summary, thereof. Nothing in this section or any Part 70 license shall alter or effect the provisions of Section 303 of the CAA (emergency orders), including the authority of EPA under Section 303; the liability of an owner or operator of a source for any violation of Applicable requirements prior to or at the time of permit issuance; or the ability of EPA to obtain information from a source pursuant to Section 114 of the CAA. The following requirements have been specifically identified as not applicable based upon the information submitted by the Licensee.

Source Citation Description Basis for Determination A. Cement Kiln Chapter 106 Low sulfur Fuel Kiln is an approved sulfur removal device B. Cement Kiln Chapter 104 Incinerator Particulate Emission Standard Kiln is not an incinerator

C. Cement Kiln Chapter 134 VOC RACT Kiln is Subject to BACT D. Cement Kiln 40 CFR Part 60, Subpart F Standards of Performance for Portland Cement Kilns Subject to 40 CFR Part 60, Subpart LLL, Portland Cement MACT

E. Coal Mill System 40 CFR Part 60, Subpart Y Standards of Performance for Coal Preparation Plants Subject to 40 CFR Part 60, Subpart LLL, Portland Cement MACT F. Cement Kiln Limestone Dryer 40 CFR Part 60, Subpart HH Standards of Performance for Lime Manufacturing Plants Dragon does not manufacture lime. Cement Kiln subject to 40 CFR Part 60, Subpart LLL, Portland Cement MACT G. Quarry Crushers 40 CFR Part 60, Subpart LL Standards of Performance for Metallic Mineral Processing Plants Not a metallic mineral
processorDragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 13

Source Citation Description Basis for Determination H. Cement Kiln 40 CFR Part 60, Subpart OOO Standards of Performance for Nonmetallic Mineral Processing Plants Subject to 40 CFR Part 60, Subpart LLL, Portland Cement MACT

I. Quarry Crushers 40 CFR Part 60, Subpart OOO Standards of Performance for Nonmetallic Mineral Processing Plants Crushers in place prior to applicability

J. Cement Kiln 40 CFR Part 60, Subpart UUU Standards of Performance for Calciners and Dryers in Mineral Industries Not a calciner or dryer and cement kiln is Subject to 40 CFR Part 60, Subpart LLL, Portland Cement MACT K. Cement Kiln 40 CFR Part 60, Subpart Eb Standard of Performance for Municipal Waste Combustors Kiln is not a municipal waste combustor.

(7) The Part 70 license shall be reopened for cause by the Department or EPA, prior to the expiration of the Part 70 license, if: (a) Additional Applicable requirements under the CAA become applicable to a Part 70 major source with a remaining Part 70 license term of 3 or more years. However, no opening is required if the effective date of the requirement is later than the date on which the Part 70 license is due to expire, unless the original Part 70 license or any of its terms and conditions has been extended pursuant to Chapter 140; (b) Additional requirements (including excess emissions requirements) become applicable to a Title IV source under the acid rain program. Upon approval by EPA, excess emissions offset plans shall be deemed to be incorporated into the Part 70 license; (c) The Department or EPA determines that the Part 70 license contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the Part 70 license; or (d) The Department or EPA determines that the Part 70 license must be revised or revoked to assure compliance with the Applicable requirements. The licensee shall furnish to the Department within a reasonable time any information that the Department may request in writing to determine whetherDragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 14

cause exists for modifying, revoking and reissuing, or terminating the Part 70 license or to determine compliance with the Part 70 license. (8) No license revision or amendment shall be required, under any approved economic incentives, marketable licenses, emissions trading and other similar programs or processes for changes that are provided for in the Part 70 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 and this license (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 140;

(3) 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; Enforceable by State-only

(4) The licensee shall pay the annual air emission license fee to the Department, calculated pursuant to Title 38 MRSA §353.

(5) 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; Enforceable by State-only

(6) The licensee shall retain records of all required monitoring data and support information for a period of at least six (6) years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the Part 70 license. The records shall be submitted to the Department upon written request or in accordance with other provisions of this license;

(7) The licensee shall comply with all terms and conditions of the air emission license. The submission of notice of intent to reopen for cause by the Department, the filing of an appeal by the licensee, the notification of plannedDragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 15

changes or anticipated noncompliance by the licensee, or the filing of an application by the licensee for the renewal of a Part 70 license or amendment shall not stay any condition of the Part 70 license.

(8) 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 under circumstances representative of the facility's normal process and operating conditions: (i) 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; (ii) to demonstrate compliance with the applicable emission standards; or (iii)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. Enforceable by State-only

(9) If the results of a stack test performed under circumstances representative of the facility's normal process and operating conditions indicates 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 aDragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 16

demonstration of compliance under normal and representative process and operating conditions. Enforceable by State-only

(10) The licensee shall maintain records of all deviations from license requirements. Such deviations shall include, but are not limited to malfunctions, failures, downtime, and any other similar change in operation of air pollution control systems or the emission unit itself that is not consistent with the terms and conditions of the air emission license.

a. The licensee shall notify the Commissioner within 48 hours of a violation in emission standards and/or a malfunction or breakdown in any component part that causes a violation of any emission standard, and shall report the probable cause, corrective action, and any excess emissions in the units of the applicable emission limitation;

b. The licensee shall submit a report to the Department on a quarterly basis if a malfunction or breakdown in any component part causes a violation of any emission standard, together with any exemption requests. Pursuant to 38 MRSA § 349(9), the Commissioner may exempt from civil penalty an air emission in excess of license limitations if the emission occurs during start-up or shutdown or results exclusively from an unavoidable malfunction entirely beyond the control of the licensee and the licensee has taken all reasonable steps to minimize or prevent any emission and takes corrective action as soon as possible. There may be no exemption if the malfunction is caused, entirely or in part, by poor maintenance, careless operation, poor design or any other reasonably preventable condition or preventable equipment breakdown. The burden of proof is on the licensee seeking the exemption under this subsection. c. All other deviations shall be reported to the Department in the facility’s semiannual report.

(11) Upon the 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.

(12) The licensee shall submit semiannual reports of any required periodic monitoring. All instances of deviations from Part 70 license requirements must be clearly identified in such reports. All required reports must be certified by a responsible official.Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 17

(13) The licensee shall submit a compliance certification to the Department and EPA at least annually, or more frequently if specified in the applicable requirement or by the Department. The compliance certification shall include the following: (a) The identification of each term or condition of the Part 70 license that is the basis of the certification; (b) The compliance status; (c) Whether compliance was continuous or intermittent; (d) The method(s) used for determining the compliance status of the source, currently and over the reporting period; and (e) Such other facts as the Department may require to determine the compliance status of the source;
SPECIAL CONDITIONS (14) Portland Cement Kiln System The requirements of this special condition apply to the existing cement kiln and the new cement kiln/raw mill alkali bypass that are emitted through the main kiln stack. A. Dragon is licensed to fire one or a combination of the following as fuel in the new or existing cement kiln [MEDEP Chapter 140]: 1. a coal/coke blend of fuel, 2. a #2-#4 fuel oil blend, 3. specification waste oil and non-specification waste oil, and 4. whole tires and tire chips.

B. In addition to the basic raw materials used in the new and the existing cement kilns (sources of calcium, iron, silica, and alumina), Dragon may also use one or a combination of the following raw materials [MEDEP Chapter 140]: 1. petroleum-contaminated soils, 2. landfill leachate, 3. petroleum-contaminated water, 4. fly ash, 5. Kraft pulp mill green liquor dregs, 6. lime mud, and lime wastes (eg. PCC Grit), 7. slaker grit. 8. foundry sand, and 9. alternative raw materials that comply with the provisions in Special Condition 14(C).

C. Use of Alternative Fuels and Raw Materials [MEDEP Chapter 140] 1. Dragon is licensed to utilize alternate fuels and raw materials in the new and existing cement kilns to the extent the material or fuels comply with all of the provisions of this subsection.Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 18

a. Proposed alternate fuels or raw materials shall not be RCRA hazardous waste according to 40 CFR Part 261 and applicable state law. This determination may be made by lab analyses or generator knowledge. b. Proposed alternate fuels or raw materials shall not be medical wastes according to 40 CFR Part 259 and/or applicable state law.

c. Proposed alternate fuels or raw materials must be determined to be acceptable by Dragon’s Alternate Fuels Management Program. d. The storage and handling of alternate fuels or raw materials shall be conducted such that fugitive emissions are minimized and are managed in accordance with applicable requirements.

e. The use of alternative fuels or raw materials would not be expected to cause an exceedance of the applicable emission limits in this license. 2. After conducting trials using the alternative fuel and/or raw material in the kiln, if Dragon proposes an ongoing use of the alternative fuel and/or raw material, Dragon shall notify the Department in writing of its intention to use an alternate fuel or raw material that meets the criteria outlined above. The notification to the Department shall include:

a. A characterization of the fuel or raw material (including results of testing that may have been performed in conjunction with trials); b. The intended use rate of the fuel or raw material; and

c. A description of the method of introduction into the kiln system. 3. In the event that the Department has not adversely responded to the notification within seven (7) calendar days of receipt of the notification provided by Dragon, then Dragon shall be allowed to implement the use of the fuels or raw materials for which notification was provided. 4. Dragon will maintain daily records of the amount of alternate fuel(s) and raw material(s) used in the process. 5. This protocol does not eliminate Dragon's obligation to comply with applicable rules nor does this protocol eliminate the need to seek the appropriate pre-construction permits when applicable. Use of alternative fuels or raw materials shall not constitute a “modification” of the existing or new kiln provided the alternative fuel or raw materials can be accommodated by the existing kiln or new kiln under its original design. 6. Within 30 days following notification of the Department by Dragon of using an alternative fuel or raw material, the Department will notify Dragon whether the use of said material would constitute a significant change of feed or fuel for purposes of performance testing requirement in 40 CFR Part 60, Subpart LLL, Section 63.1349(e).

D. Dragon shall operate a particulate matter control device (fabric filter-type) to control particulate emissions from the existing kiln and from the new cement kiln and alkali bypass. Broken bags do not constitute violations of this license unless the broken bag also causes an exceedance of an applicable emission limit. [40 CFR Part 63 Subpart LLL]Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 19

E. The three-hour rolling average baghouse inlet temperature shall not exceed the maximum demonstrated particulate matter control device (PMCD) inlet temperature as determined during dioxin/furan compliance testing in accordance with 40 CFR Part 63.1344(b). Inlet temperature monitoring and the inlet temperature limitation shall only apply to the inlet of the main kiln baghouse. [40 CFR Part 63 Subpart LLL].

F. Beginning 180 days after the new cement kiln systems are maintained for an hour above 30 TPH (tons per hour) of dry feed to the kiln, emissions from the new dry process cement kiln system shall not exceed the limits set forth below. Emissions from the new cement kiln system include emissions from the in-line raw mill and alkali (preheater) bypass that are emitted from the common main kiln stack.

Pollutant Limit Units Ave Time Method of Compliance Demonstration Origin & Authority

9.4 lb/hr N/A MEDEP Chapter 115, BACT PM

0.3 lb/ton dry kiln

feed N/A Stack Test,Method 5 (fronthalf only), once every other year for PM 40 CFR 63, Subpart LLL

9.4 lb/hr N/A PM 10

0.3 lb/ton dry kiln

feed N/A When Requested by the Department MEDEP Chapter 115, BACT

SO 2 1,000. 0 3 lb/hr 1-hour block average CEM MEDEP Chapter 115, BACT 70.0 lb/hr 90-day rolling average 1 306.6 ton/yr 12-month rolling 1 total, calculated at

the end of each calendar month.Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 20

Pollutant Limit Units Ave Time Method of Compliance Demonstration Origin & Authority

1,200.0 3 lb/hr 1-hour block average 350.0 lb/hr 90-day rolling average 1 NO x 4

1,533.0 ton/yr 12-month rolling 1 total, calculated at

the end of each calendar month CEM MEDEP Chapter 115, BACT

500.0 3 lb/hr 1-hour block average 192.5 lb/hr 90-day rolling average 1 CO

843.2 ton/yr 12-month rolling 1 total, calculated at

the end of each calendar month CEM MEDEP Chapter 115, BACT

13.13 lb/hr 1-hour(based on the average of at least three one-hour stack tests) VOC

57.5 ton/yr 12-month rolling 1 total, calculated at

the end of each calendar month Stack Test and emission factor MEDEP Chapter 115, BACT

Dioxins/

Furans 0.40 2 ng TEQ/ dscm @7% O 2 and PMCD inlet temp. ≤ 400 o F 2 Stack Test 40 CFR Part 63 Subpart LLL

1. Rolling averages are calculated as consecutive days or months and include operating and nonoperating days 2. Unless Dragon can demonstrate compliance with the allowable 40 CFR 63 Subpart LLL dioxin/furan limitation for particulate matter control device inlet temperatures greater than 400 o F. 3. Enforceable by State Only 4. NO x reported as NO 2Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 21

G. Emissions from the existing cement kiln system shall not exceed the limits set forth below. Emissions from the existing cement kiln system include emissions that are emitted from the main kiln stack.

Pollutant Limit Units Ave Time Method of Compliance Demonstration Origin & Authority

37.7 lb/hr 1-hour(based on the average of atleast three onehour stack tests) MEDEP Chapter 115, BACT PM/ PM 10

0.3 lb/ton dry kiln

feed N/A Stack Test,Method 5 (fronthalf only), once every other year for PM 40 CFR Part 63 Subpart LLL

600 lb/hr 1-hour block average SO 2
103 lb/hr 90-day rolling average 1 CEM MEDEP Chapter 115, BACT

1227 lb/hr 1-hour block average NO x 3

514 lb/hr 90-day rolling average 1 CEM MEDEP Chapter 115, BACT

CO 500.0 lb/hr 1-hour block average Stack Test and emission factor MEDEP Chapter 115, BACT

VOC 7.2 lb/hr 1-hour block average Stack Test and emission factor MEDEP Chapter 115, BACT Dioxins/

Furans 0.40 2 ng TEQ/ dscm @ 7% O 2 and PMCD inlet temp. ≤ 400 o F 2 Stack Test 40 CFR Part 63 Subpart LLL

1. Rolling averages are calculated as consecutive days and include operating and non-operating days. 2. Unless Dragon can demonstrate compliance with the allowable 40 CFR 63 Subpart LLL dioxin/furan limitation for PMCD inlet temperatures greater than 400 o F. 3. NO x reported as NO 2

H. Dragon shall operate the new and the existing cement kiln systems such that the visible emissions from main kiln stack do not exceed twenty (20) percent opacity on a six (6) minute block average basis, except for not more than one six minute block average in a one-hour period. When the exhaust, as measured at the kiln ID fan, is less than 250 o F, monitored opacity readings greater than 20% as measured on a six (6) minute block average basis are not considered an excess emission. [MEDEP Chapter 140, BPT, 40 CFR Part 63 Subpart LLL]Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 22

I. Compliance with VOC and dioxin/furan emission standards shall be demonstrated by stack test when requested by the Department. However, dioxin/furan testing will be no less frequent than specified in 40 CFR 63 Subpart LLL. [MEDEP Chapter 140 and 40 CFR Part 63 Subpart LLL] J. Dragon shall perform a one-time initial stack test on the new kiln for VOC emissions during the first dioxin/furan test. [MEDEP Chapter 140, BPT, Enforceable by State Only ]

K. Beginning 180 days after the new cement kiln systems are maintained for an hour above 30 TPH (tons per hour) of dry feed to the kiln, Dragon shall demonstrate compliance with emission standards for SO 2 , NO x and CO at all times, except during periods of startup, shutdown, or malfunction of the kiln system, in accordance with Chapter 117 of the Department regulations, as specified in Special Condition 23(C) below. Emissions shall be determined using CEMS data and the stack flow rate, and Dragon shall monitor and record the new cement kiln stack flow rate. Stack flow will either be calculated using fan curve information or will be directly measured. If a monitor is used stack flow rate data shall be monitored and recorded at the same frequency as monitoring and recording occurs for SO 2 and NO x ppmvd data. [MEDEP Chapter 117 for NO x and CO; Chapter 140, BPT for SO 2 [SO 2 CEM enforceable by State only]]

L. Compliance with the PM lb/hr emission limits shall be demonstrated by biennial stack testing and conducted in accordance with 40 CFR Part 63.1349. Dragon shall conduct stack testing for particulate matter emissions from the new cement kiln stack with 180 days after the new cement kiln system becomes fully operational and every other year thereafter. [MEDEP Chapter 140 BPT, 40 CFR Part 63 Subpart LLL]

M. Following a 180-day initial start up of the new cement kiln, Dragon shall monitor NO x and SO 2 emissions for a period of one year and perform a statistical analysis of the monitored emission rates. Dragon shall submit a copy of the statistical analysis to the Department within 60 days of completion of the one year period. This statistical analysis will be used by the Department to evaluate final BACT limits for NO x and SO 2 . [MEDEP Chapter 140, BPT, Enforceable by State only ]Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 23

N. Dragon shall monitor and record the following parameter monitors as specified:

Parameter Monitor Record Origin & Authority Kiln baghouse inlet temperature (See Note 1) Continuously Continuously 40 CFR Part 63 Subpart LLL Fan Speed (See Note 2) Continuously Continuously Chapter 140 BPT

Each parameter monitor must record accurate and reliable data. If the parametermonitor is recording accurate and reliable data less than 98% of the sourceoperating time within any quarter of the calendar year, the Department may initiate enforcement action and may include in that enforcement action any period of time that the parameter monitor was not recording accurate and reliable data during that quarter unless the licensee can demonstrate to the satisfaction of the Department that the failure of the system to record accurate and reliable data was due to the performance of established quality assurance and quality control procedures or unavoidable malfunctions. [MEDEP Chapter 140 BPT]

Note (1): The three-hour rolling average temperature shall be calculated as the average of 180 successive one-minute average temperatures. Continuous monitoring and recording requirements will comply with 40 CFR 63 Subpart LLL.

Note (2): Fan speed shall be monitored and recorded at the same frequency as monitoring and recording occurs for SO 2 and NO x ppmvd data. In the event that Dragon installs a flow meter on the kiln stack, the fan speed monitoring will not be required.

(15) The beneficial use of off-site waste water in the new or existing cement kiln, including landfill leachate and petroleum contaminated waters, shall be limited to 50,000 gallons per day. [MEDEP Chapter 140 BPT]

(16) Clinker Cooler The requirements of this special condition apply to the emission source U053. A. Dragon shall operate a fabric filter (baghouse) on the clinker cooler to control particulate matter emissions. Dragon shall operate, maintain and monitor this source in accordance with the requirements of 40 CFR 63 Subpart LLL. [MEDEP Chapter 140 BPT and 40 CFR 63 Subpart LLL]

B. Particulate matter (PM) emissions from the clinker cooler shall not exceed 9.15 lb/hr or 0.1 lbs/ton dry kiln feed. [MEDEP Chapter 140 BPT and 40 CFR 63 Subpart LLL]Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 24

C. Dragon shall operate the clinker cooler such that the visible emissions from its stack do not exceed ten (10) percent opacity on a six (6) minute block average basis. Monitoring for opacity shall be conducted by a Continuous Opacity Monitor (COM). In accordance with 40 CFR Part 63.6(h)(1), exceedances of this standard during startup, shutdown, or malfunctions are not considered violations of the opacity limit in Subpart LLL. [MEDEP Chapter 140 BPT and 40 CFR 63 Subpart LLL]

D. Dragon shall conduct stack testing for particulate matter emissions from the clinker cooler once every other year coincident with testing of the new kiln. [MEDEP Chapter 140 BPT]

(17) Finish Mills The requirements of this special condition apply to the pre-grinding mill vent, source U766. A. Dragon shall operate and maintain fabric filters for particulate matter control on these sources. [MEDEP Chapter 140 BPT]
B. Visible emissions from each of the sources listed above and the fabric filters shall not exceed ten (10) percent opacity on a six (6) minute block average basis. In accordance with 40 CFR Part 63.6(h)(1), e of the opacity limit in Subpart LLL [40 CFR 63 Subpart LLL] C. The particulate matter emission rates from the finish mills fabric filter systems shall not exceed the applicable limit set forth in Table 105A of Chapter 105 of the Department’s regulations. [MEDEP Chapter 105] D. Operation, maintenance, and monitoring of the finish mill fabric filters shall be conducted in accordance with Subpart LLL requirements. These requirements include the preparation of an Operations and Maintenance Plan, daily visible emissions monitoring, and periodic Method 9 performance tests. [40 CFR 63 Subpart LLL]

(18) Other Portland Cement MACT Sources The requirements of this special condition apply to the following sources, as well as to those emission units subject to 40 CFR Part 63, Subpart LLL that are insignificant (with respect to Chapter 140 permitting purposes) and not specifically listed in this License but are also authorized for construction and operation by the License.Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 25

Emission Unit ID Emission Unit Name

U203 Rock Silo #1 U445 Weighfeeders from Silos 1, 2, and 4 U447 Weighfeeders from Silos 5 and 6 U460 Raw Mill Fugitive Sources U506 Raw Mill Fugitive U511 Below Raw Mill Cyclones U767 Pregrinder Product Transport U785 FM #1 Mill Feed U828 Kiln Feed Bin U830 Homogenizing Silo Top Clinker Reclaim Tunnel

A. Visible emissions from each of the sources listed above and the fabric filters shall not exceed ten (10) percent opacity on a six (6) minute block average basis. In accordance with 40 CFR Part 63.6(h)(1), e of the opacity limit in Subpart LLL [MEDEP Chapter 140 BPT and 40 CFR 63 Subpart LLL]

B. The particulate matter emission rates from the equipment referenced above shall not exceed the applicable limit set forth in Table 105A of Chapter 105 of the Department’s regulations. [MEDEP Chapter 105]

C. Operation, maintenance, and monitoring of these emission sources shall be conducted in accordance with Subpart LLL requirements. These requirements include the preparation of an Operations and Maintenance Plan, monthly visible emissions monitoring, and periodic Method 9 observation tests. [40 CFR 63 Subpart LLL]

(19) Other Process and Fugitive Sources The requirements of this special condition apply to those emission units that are not subject to Subpart LLL and are insignificant (with respect to Chapter 140 permitting purposes) and not specifically listed in this License but are also authorized for construction and operation by the License.

A. Visible emissions from each of the fabric filters shall not exceed 20 percent opacity on a six (6) minute block average basis. [MEDEP Chapter 140 BPT]Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 26

(20) Visible emissions from fugitive emission sources (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 is determined by an aggregate of the individual fifteen (15)-second opacity observations which exceed 20 percent in any one (1) hour. [MEDEP Chapter 140 BPT]

(21) Stack Testing A. Dragon shall conduct testing and submit test reports in accordance with 40 CFR Part 63 Subpart LLL, Section 63.1349. [40 CFR 63 Subpart LLL]
B. All stack testing programs shall comply with the requirements of the MEDEP Compliance Test Protocol and with 40 CFR Parts 60 or 63, as appropriate, or other methods approved by the MEDEP and EPA. [MEDEP Chapter 140 BPT]
C. All initial performance tests required by this permit shall be completed within 180 days of initial startup. [40 CFR 63 Subpart LLL]

(22) Dragon shall meet the notification requirements in 40 CFR Part 63 Subpart LLL, Section 63.1353. [40 CFR 63 Subpart LLL]

(23) Record-Keeping [MEDEP Chapter 140, BPT and 40 CFR Part 63 Subpart LLL] Dragon shall comply with the recordkeeping requirements in 40 CFR Part 63 Subpart LLL, Section 63.1355. A. The following periodic records shall be kept: 1. Summary page of the results of stack testing for PM, PM 10 , SO 2 , NO x , CO and VOC for the main kiln stack when performed. 2. Summary page of the results of bi-ennial stack testing for particulate matter emissions from the clinker cooler. 3. Summary page of the results of stack testing for dioxin/furans required by Subpart LLL every 2.5 years. 4. Summary of the daily visual observations of finish mill. 5. Summary of the periodic Method 9 performance tests on the finish mill. 6. Summary of the annual inspection of the components of the combustion system and raw mill. 7. Summary of the daily records of fuel use in the kiln including:

a. Gallons of #2 fuel oil b. Gallons of #4 fuel oil c. Gallons of specification waste oil and non-specification waste oil d. Tons of coal e. Tons of petroleum cokeDragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 27

f. Tons of fly ash g. Tons of tires or tire chips 8. Summary of the quantity of off-site waste water, including landfill leachate and petroleum contaminated waters, used each day. B. The following parameter monitor records shall be kept. 1. Fan speed or stack flow rate. 2. Kiln baghouse inlet temperature.
C. For all CEMS and COMS , the following records shall be kept: 1. Documentation that all CEMS and COMS are continuously accurate, reliable and operated in accordance with Chapter 117, 40 CFR Part 51, Appendix P, and 40 CFR Part 60, Appendices B and F; [MEDEP Chapter 117] 2. Records of all measurements, performance evaluations, calibration checks, and maintenance or adjustments for each CEMS and COMS as required by 40 CFR Part 51 Appendix P; 3. A report of other data indicative of compliance with the applicable emission standard for those periods when the CEMS or COMS were not in operation or produced invalid data. In the event the Department does not concur with the licensee’s compliance determination, the licensee shall, upon the Department’s request, provide additional data, and shall have the burden of demonstrating that the data is indicative of compliance with the applicable standard. [MEDEP Chapter 117]

(24) Dragon shall comply with the Reporting requirements in 40 CFR Part 63 Subpart LLL, Section 63.1354. [40 CFR 63 Subpart LLL] (25) Quarterly Reporting The licensee shall submit a Quarterly Report to the Bureau of Air Quality within 30 days after the end of each calendar quarter, detailing the following, for the control equipment, parameter monitors, Continuous Emission Monitoring Systems (CEMS) required by this license. [MEDEP Chapter 117]

1. All control equipment downtimes and malfunctions; 2. All CEMS downtimes and malfunctions; 3. All parameter monitor downtimes and malfunctions; 4. All excess events of emission and operational limitations set by this Order, Statute, state or federal regulations, as appropriate. The following information shall be reported for each excess event; a. Standard exceeded; b. Date, time, and duration of excess event;Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 28

c. Maximum and average values of the excess event, reported in the units of the applicable standard, and copies of pertinent strip charts and printouts when requested; d. A description of what caused the excess event; e. The strategy employed to minimize the excess event; and f. The strategy employed to prevent reoccurrence. 5. A report certifying there was no excess emissions, if that is the case.

(26) Semiannual Reporting The licensee shall submit semiannual reports every six months to the Bureau of Air Quality. The semiannual reports are due on July 31 st and January 31 st of each year with the initial semiannual report due July 31, 2004 . The semiannual report shall be considered on-time if the postmark of the submittal is before the due date or if the report is received by the DEP within seven calendar days of the due date. A. Each semiannual report shall include a summary of the periodic monitoring required by Condition (23)A of this license. B. All instances of deviations from license requirements and the corrective action taken must be clearly identified and provided to the Department in summary form for each six-month interval. [MEDEP Chapter 140]

(27) Annual Compliance Certification Dragon shall submit an annual compliance certification to the Department in accordance with Standard Condition (13) of this license. The initial annual compliance certification is due January 31 of each year with the initial annual certification due January 31, 2005 . The annual compliance certification shall be considered on-time if the postmark of the submittal is before the due date or if the report is received by the DEP within seven calendar days of the due date. Certification of compliance is to be based on the stack testing or monitoring data required by this license. Where the license does not require such data, or the license requires such data upon request of the Department and the Department has not requested the testing or monitoring, compliance may be certified based upon other reasonably available information such as the design of the equipment or applicable emission factors. [MEDEP Chapter 140]

(28) Annual Emission Report 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; ORDragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 29

2. A written emission statement containing the information required in MEDEP Chapter 137. Reports and questions should be directed to: Attn: Criteria Emission Inventory Coordinator Maine DEP Bureau of Air Quality 17 State House Station Augusta, ME 04333-0017 Phone: (207) 287-2437

The emission statement must be submitted no later than September 1 or as otherwise specified in Chapter 137.

(29) The licensee is subject to the State regulations listed below.

Origin and Authority Requirement Summary Enforceability Chapter 102 Open Burning - Chapter 109 Emergency Episode Regulation - Chapter 110 Ambient Air Quality Standard - Chapter 116 Prohibited Dispersion Techniques - 38 M.R.S.A. §585-B, sub-§5 Mercury Emission Limits Enforceable by State-only

(30) Units Containing Ozone Depleting Substances When repairing or disposing of units containing ozone depleting substances, the licensee shall comply with the standards for recycling and emission reduction pursuant to 40 CFR Part 82, Subpart F, except as provided for motor vehicle air conditioning units in Subpart B. [40 CFR, Part 82, Subpart F] (31) Asbestos Abatement Activities When undertaking Asbestos abatement activities, Dragon shall comply with the Standard for Asbestos Demolition and Renovation 40 CFR Part 61, Subpart M. [40 CFR Part 61, Subpart M]

(32) The licensee shall comply with all applicable requirements of 40 CFR Part 68 (Risk Management Plan).

(33) Certification by a Responsible Official All reports (including quarterly reports, semiannual reports, and annual compliance certifications) required by this license to be submitted to the Bureau of Air Quality must be signed by a responsible official. [MEDEP Chapter 140]Dragon Products Company, Inc. Departmental Knox County Findings of Fact and Order Thomaston, Maine Part 70 Air Emission License A-326-70-A-I 30

(34) Dragon shall pay the annual air emission license fee within 30 days of June 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. [38 MRSA §353-A]

(35) 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 2003.

DEPARTMENT OF ENVIRONMENTAL PROTECTION

By:_______________________________________________________ DAWN R. GALLAGHER, COMMISSIONER

PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES

Date of initial receipt of Part 70 application October 28, 1997 Date of Part 70 application acceptance October 28, 1997

Date filed with Board of Environmental Protection_________________________

This Order prepared by Mark E. Roberts, Bureau of Air Quality