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Departmental Findings of Fact and Order
Part 70 Air Emission License
A-326-70-A-I

Dragon Products Company, Inc.
Knox CountyThomaston, Maine

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

NOx 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 NOx 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 oF, 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, SO2, and NOx 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.