- 1 - AMENDMENT TO ENVIRONMENTAL ANALYSIS AND DECISION ON THE NEED FOR AN ENVIRONMENTAL IMPACT STATEMENT (EIS) Department of Natural Resources (DNR)

Revised 7-2006

Title of Original Environmental Assessment: Wis. PSC – WE Energies(WEPCO) 50 MW Biomass-Fueled Cogeneration Facility at Domtar Paper Mill, Village of Rothschild, Marathon Co. (2010)

Region or Bureau DNR WCR

Type List Designation NR 150.03(b)(1)(a), type II action, Air Pollution
Control Permit

Contact Person: Jeffery Johnson

Title: Environmental Engineering Supervisor

Address: West Central Region Headquarters, 1300 W. Clairemont Ave., PO Box 4001, Eau Claire, WI

54701

Telephone Number: (715) 838-8387

E-mail Address: Jeffery.Johnson@wisconsin.gov

Project name: Wisconsin Electric Power Company Application for Air Pollution Control Permits for Construction and Operation of a 50 Megawatt Biomass-Fueled Cogeneration Fac ility at Domtar Paper Mill, Rothschild

Applicant: Wisconsin Electric Power Company (WEPCO) (subsidiary of WE Energies)

Address: 231 W Michigan St., Milwaukee, WI 53203 (anot her listed address is 333 West Everett Street)

Title of Proposed Amendment: Amendment to Wisconsin Public Service Commiss ion (PSC) Environmental Assessment (EA) for WEPCO Application for Certificate of Authority (CA)(per PSC 4.10(2), Wis. Adm. Code) for Construction and Operation of a 50 MW Biomass-Fueled Cogeneration Facility (2010). This Departme nt of Natural Resources (DNR) Amendment to PSC’s EA is prepared pursuant to NR 150.20(2)(f)(2) for consideration of Air Pollution Control Permits.

Location: County: Marathon City/Town/Village: Village of Rothschild

Township Range Section(s): Sections 23, 24, 25, 26, T28N, R7E

AMENDMENT SUMMARY

Describe the nature of proposed amendments to the orig inal assessment and the reasons for the change.

WEPCO is proposing to construct, install and place in operation equipment that will co mbust biomass to provide 50 megawatts (M W) electricity generation capacity and steam in a circulating fluidized bed boiler and a backup natural gas fired auxiliary boiler on 13.3 acres at an existing Domtar Corporation paper mill in Rothschild, WI. The site is currently used by Domtar for log and chip sto rage and vehicle access/parking and 12.8 acres are paved/graveled. Generated electricity would be provided to WEPCO customers and steam provided to Domtar for continued operation of the paper mill. The new WEPC O biomass boiler would replace four existing Domtar boilers. Existing Domtar industrial water supply and wast ewater systems would be adequate for use in the new biomass energy facility. Minor changes for bioma ss fuel handling/storage and access gate/roadw ays would be made at the existing mill s ite.

The project requires a PSC Certificate of Authority (CA), for which PSC is first requ ired to prepare an environmental assessmen t to identify and consider potential project environmental impacts prio r to a CA decision. PSC completed their EA on October 22, 201 0. A- 2 - copy of PSC’s EA is available on the PSC’s Electr onic Regulatory Filing (ERF) at the following links: EA: http://psc.wi.gov/apps35/ERF_view/viewdoc.aspx?docid=140452 EA Attachments: http://psc.wi.gov/apps 35/ERF_view/viewdoc.aspx?docid=140453 They may also be accessed by going to the PSC web site, http://psc .wi.gov/, and click on “ERF – Electronic Regulatory Filing” a nd “Search ERF.” Type in the PSC docket number 6630-CE-305 and hit “Go.” Scroll to PSC Reference #s 140452 (Exhibit 13.1) and 140453 (Exhibit 13.1 attachments). Click on thes e to get pdf’s of the two pieces of the EA.

A PSC decision on the CA is pending.

DNR permits are also required for the project:

 Air pollution control construction and operation (ch. NR 405, 406, and 407, Wis. Adm. Code).

 WPDES permit for construction site erosion control and stormwater management/discharges (NR 216 and 151, Wis. Adm. Code).

 Enlargement (unconnected) to Navigable Waterway (stormwater retention basin within 500’ of Wisconsin River) (Cpt. 30, Wis. Stats.).

 Possible waterway crossing or wetland fill permit/approval for transmission line connection, alternatives routes still being considered (wetland fill alterna tive is allowable only if no other practical alternatives can be demonstrated by WEPCO)

Of the permits listed above, only the air permits require DNR to pr epare an EA per NR 150, Wis. Adm. Code. Though DNR initially intended to complete its own EA, independent of that prepared by PSC, it became apparent that such efforts would be redundant. After consultation the agencies d ecided DNR would cooperate in the development of PSC ’s EA and then, as needed, DNR would prepare an EA Amendment to that document. This environmental review appro ach is consistent with NR 150.20(2)(f)(2), Wis. Adm. Code, which allows DNR to “adopt an environmental analysis prepared by another agency as the department’s EA...” if the other agency EA meets the substantive requirements describe d in NR 150.22, Wis. Adm. Code. DNR subsequently worked cooperatively in the development of PSC’s EA, both broadly and also particularly in regard to PSC’s analysis of is sues/impacts related to DNR permit jurisdiction. This arrangement helped assure that PSC’s EA was comprehensive in scope and findings/conclusions, meeting the

substantive standard listed in NR 150.22.

There are three issues that wa rranted additional attention by DNR in this EA Amendment.

First, when considering air permits DNR’s standard review process is to take applicant data and then conduct its own independen t analysis, using USEPA-approved modeling technology, to make its own conclusions whether the project will comply with air qualit y standards. DNR will add enforceable equipment or operati onal controls to ensure emission standards are met.

The DNR uses dispersion modeling to evalua te the ambient air impact of air pollution sources. The following is a brief descrip tion of how that process works. A model is a mathem atical simulation, designed to predict what can or will happen in real-world scenari os. Atmospheric dispersion modeling is useful in predicting the imp act a particular facility will have with respect to a given poll utant. The major benefit of dispersion modeling is that it is an inexpensiv e way to assess the impact of a source. This information is vit al in assessing a facility’s compliance with respect to the National an d State Ambient Air Quality Standards (NAAQS) and increments a s well as the various Hazardous Air Pollutant (HAP) standards, both federal and state. Dispersion modeling incorporates informati on about a facility, such as source/stack parameters, facility layout information, and emission rates, along with 5 years of meteo rological data, in order to predict concentrations of pollutants in the vicinity of the facility. The point of highest impact is determin ed through the use of a receptor grid that is set up by the modeler, and could be the result of (besides other factors) inversions. The po llutant concentration at the point of highest impact is added to a previo usly determined background concentration and then is compared to the corresponding ambient air quality standard.

All modeling completed in the State of Wisconsin for use by DNR is conducted in accordance with these DNR procedures as well as guidance contained in the Guideline on Air Quality Models, EPA document 40 CFR part 51, Appendix W. The present USEPA approved dispersion model is AERMOD. This model is used for all dispersion modeling conducted for or by the DNR.

The PSC EA was prepared before DNR had done its independent analysis. Therefore conclusions in the PSC EA relative to air emissions are solely based on WEPCO’s proposed control technology and their projected air emissions and impacts. DNR’s air analysis is now complete and this EA Amendment discusses the re sult of that independent analysis, including the air dispersion modeling analysis.

The second subject addressed in this EA am endment is in response to public interest and comments this project has generated. Si nce WEPCO’s air permit application was first subm itted to DNR in March, 2010 we received a steady stream of emails, letters and cal ls from concerned citizens about potential project impacts. Most contacts came from sources concerned about or opposed to the proj ect, the majority from a citizens group called Saving Our Air Resour ce (SOAR). Prevailing points were that the project air emissions- 3 - would adversely impact public health of nearby residents and schools and that DNR should prepare an environmental impact statement for the project. Initially DNR responded to such contacts on a one-to-one basis, often responding that we would try t o address specific concerns when we complete d our project review. Such responses often generated more questions, frequently raisi ng the same points by the same people or groups. One frequent commenter provided a comprehensive list of 23 issues/questions that seemed to represent most of the public conc erns being generated. In effort to keep track of these issues DNR promised it would include the list, along with DNR responses, in its EA Amendment - see Attachment A. Many, if not all, of the same issues are al so addressed in PSC’s EA.

Third, according to an AECOM Technical Services, Inc. (WE environmental consultant) 12/14/10 draft report a geotechnical exploration and analysis identified localized soil contaminati on at the site. Two 2009 soil borings showed evidence of soil contamination. An environmental soil investigation was conducted around and adjacent to these two boring locations in October 2 010. Soil samples were collected from 15 borings. The limited soil i nvestigation identified additional soil contamination in the are a. The contaminants in the soil were metals (primarily lead and arseni c), polynuclear aromatic hydrocar bons (PAHs), trichloroethene, v inyl chloride, trans-1,2-dichloroethene, and cis-1,2-dichloroethene. Soil samples for laboratory analysis were taken at depths rang ing from 1’ to 10’ below ground surface. The extent of soil contamination has not yet been fully defined. Additional investigation, in consultation with DNR, is being planned to determine horizontal and vertical extent of the contamination. In some areas ground water samples must be collected to determine if groundwater has been impacted. After the additional investigation has been completed , the remedial options can be evaluated in accord ance with requirements of Wisconsin’s Hazar dous Substances Spill Law, sec. 292.11, W is. Stats. and Chapter NR 700, Wis. Administrative Code. It is DNR ’s understanding that unsuitable geotechnical fill will be remove d

from the construction area. If this material is contaminated , it must be managed in accordan ce with all applicable rules.

As to procedural requirements of NR 150 for this EA Amendmen t and those associated with DNR permits, DNR is following it’s own processes independent of PSC regulations. Opportunities for public review and comment on DNR’s EA Amendment and air pollution control permits will be separately noticed from PSC’s public revi ew process. Public comments prov ided to DNR will be considered independently by DNR prior to decisions on DNR environmental review compliance and permit issuance.

DNR EVALUATION

Discuss the adverse and beneficial impacts not addressed in the or iginal EA that would result from the amended action, and any additional alternatives

considered.

Air Emissions Information below summarizes the results of DNR’s independent review of applicant-provided information and supplements air impacts information provided in PSC’s EA.

A. Construction Impacts

PSC’s EA considers potential project construction impacts on air quality in section 2.1.1. No major impacts are expected. Due t o the pre-existing industrial uses at the Domtar site only minor excav ation and earth work is anticipated for planned new facilities. Any future remedial action for soil contamination (see previous summary section of EA) is not expected to impact air quality. The a ir pollution regulations do include requirements for certain levels of soil remediation activities, and those would be implemented if necessary. Fugitive dust during construction would be minimized by best management practices which include paving or placing gravel on access roads and equipment lay down and watering down roads or work areas with tanker trucks as needed. Diesel emissi ons from construction equipment would be temporary and minor.

B. Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis

PSC’s EA considers potential project operational impacts to air quality in section 2.2.1.1- 2.2.1.5 (Attachment B). The followi ng describes the findings of DNR’s independent analysis.

B.1. Potential Emissions from the Facility

The following tables represent the potential emissions from the facility once constructed and operating under the terms of the draft DNR air pollution control permit.- 4 - Table 1a. Criteria Air Polluta nt Emissions (including re gulated fugitive sources)

Potential to Emit (PTE)

Pollutant Pounds per hour Tons per year

PM 30.1 132

PM10 30.1 132

PM2.5 22.1 97

SO2 8.9 39

NOx 84.31 363.7

CO 117 485.6

VOC 15.7 66.1

Fluorides 1.02 4.17 Mercury 0.00016 0.0007

Lead 0.024 0.11

Sulfuric acid mist 1.4 6.3

Table 1b. Hazardous Air Pollutant Emissions

Contaminant Emission Rate (pounds per hour)

Antimony 0.006

Arsenic 0.018 Beryllium 0.001

Cadmium 0.003

Chromium 0.017
Chromium,-hexavalent 0.003

Cobalt 0.005

Lead 0.038 Manganese 1.28

Nickel 0.026 Phosphorus 0.022

Selenium 0.002 Hydrogen-chloride 14.4 Hydrogen-fluoride 0.8 Acetaldehyde 0.664

Acrolein 0.0601

Benzene 3.36 Benzo(a)anthracene 0.000052 Benzo(b)fluoranthene 0.00008 Benzo(e)pyrene 0.000002 Benzo(g,h,i)perylene 0.000074 Benzo(j,k)fluoranthene 0.000128 Benzo(k)fluoranthene 0.000029 bis(2-Ethylhexyl)phthalate 0.000038

Bromomethane 0.012

2-Butanone 0.004

Carbon-tetrachloride 0.036

Chlorine 0.632

Chlorobenzene 0.026

Chloroform 0.022- 5 - Contaminant Emission Rate (pounds per hour)

Chloromethane 0.018 1,2-Dibromoethene 0.044 Total-Polychlorinated-biphenyls-(PCB) 0.000006 Total-Equiv.-2,3,7,8-TCDD-(Dioxins) 0.000002 1,2-Dichloroethane-(EDC) 0.023

Dichloromethane 0.232 1,2-Dichloropropane 0.026 Ethyl-benzene 0.025 Formaldehyde 3.52 Indeno(1,2,3,c,d)pyrene 0.0000696 2-Methylnaphthalene 0.000128 Naphthalene 0.078 4-Nitrophenol 0.000088 Pentachlorophenol-(PCP) 0.0000408

Phenol 0.041 Propanal-(Propionaldehyde) 0.003 Propionaldehyde 0.049 Styrene 1.52 Tetrachloroethene-(Perchloroethylene) 0.03

Toluene 0.736
1,1,1-Trichloroethane 0.025

Trichloroethene 0.024 Trichlorofluoromethane-(CFC?11) 0.033 Vinyl-Chloride 0.014 o-Xylene 0.02 Mercury 0.002

Table 1c. Greenhouse Gas Emissions

Source Potential to Emit Pounds per Hour on a

CO 2 equivalent basis Tons per Year on a

CO 2 equivalent basis Biomass boiler 180,321 789,805 Natural gas boiler 42,086 130,468 Total 222,407 920,273

B.2. Ambient Air Dispersion Modeling and Risk Analysis

Three distinct air dispersion modeling and risk analyses have b een completed, as outlined below. The first section provides the analysis completed for the air pollution cont rol permit. The second section contains an additional analysis for specific recept ors and the air quality index review. The third and final section contains a risk analysis fo r selected hazardous air pollutants. The s econd and third sections are analyses not typically conducted for air po llution control permits, rather are additional analyses conducted for purposes of responding to numerous public inquiries regarding the pr oposed project to be included within this environmental ana lysis.

The DNR uses dispersion modeling to evalua te the ambient air impact of air pollution sources. The following is a brief descrip tion of how that process works.

A model is a mathematical simulation, designed to predict what can or will happen in real-world scenarios. Atmospheric dispersi on modeling is useful in predicting the impact a particular facility will have with respect to a given pollutant. The major benefi t of dispersion modeling is that it is an inexpe nsive way to assess the impact of a source. This information is vital in assessing a facility’s compliance with respect to the National and State Ambient Air Quality Standards (NAAQS) and increments as well as the various Hazardous Air Pollutant (HAP) standa rds, both federal and state.- 6 - Dispersion modeling incorporates information about a facility, su ch as source/stack parameters, facility layout information, an d emission rates, along with 5 years of meteorological data, in order to predict concentrations of pollutants in the vicinity of the facility. The point of highest impact is determined through the use of a receptor grid that is set up by the modeler, and could be the re sult of (besides other factors) inversions. The pollutant concentration at the point of highest impact is added to a previously determi ned background concentration and then is compared to the corresponding ambient air quality standard.

All modeling completed in the State of Wisconsin for use by DNR is conducted in accordance with these DNR procedures as well as guidance contained in the Guideline on Air Quality Models, EPA document 40 CFR part 51, Appendix W. The present USEPA approved dispersion model is AERMOD. This model is used for all dispersion modeling conducted for or by the DNR.

According to the findings of the air quality analysis (air di spersion modeling) under permit action 10-SDD-058, the emissions f rom the facility (and nearby sources that contribute to impacts) w ill attain and maintain the NAAQS, which are set to protect publi c health and welfare. Those standards (NAA QS) are set at levels such that the most susceptible populations (children, elderly, and peopl e with respiratory conditions) are protected.

B.2.1. Ambient Air Dispersion Modeling for Air Pollution Control Permit 10-SDD-058

Introduction WE Energies (WE) has submitted to the Wisconsin Department of Natural Resources (WDNR) an air permit application for the installation of one new biomass-fired boiler and one new natural gas-fired package boiler. To support the biomass-fired boiler, the Project will require new biomass fuel handling equipment, bioma ss boiler ash handling equipment, and a new cooling tower. Under the Prevention of Significant Deterioration (PSD) program in Wi s. Adm. Code NR § 405.02(22)(a), the major stationary source threshold for this facility is 100 tons per year. Based on the potential emissions, the Project will be a major PSD source and requires PSD air quality analyses for carbon monoxide (CO), nitrogen oxides (NO X ), particulate matter (PM/PM 10 ), and particulate matter less than 2.5 microns in diameter (PM 2.5 ). In addition, emissions of l ead (Pb) were also modeled.

Air quality impacts are assessed through an air quality disper sion modeling analysis. In addition to the proposed facility, sev eral additional sources were included as they may provide additional impact in the area of the proposed project. The additional sour ces included in the modeling analysis are: Domtar, Lignotech, and the four main boilers at Wisconsin Public Service Corp. - Weston (Units 1, 2, 3, and 4). Diesel exhaust emissions off-site are not regulated by the proposed stationary source air pollution con trol permit. While emissions from diesel exhaust specific to this facility/pro ject are not directly included in an air quality dispersion mo deling analysis, they are indirectly through inclusion of background. Di esel exhaust (mobile source) emissions are included in the air quality dispersion model only as part of the background concentrations, which is added to the total impact from the stationary source e mission impacts and do show attainment of the ambient air quality standards.

Recommendation Assuming the emission rates, building dimensions, stack parameters and all other restriction set forth in the ‘Air Dispersion A nalysis in support of a PSD Permit Application for WE Energies - Roth schild (Marathon County)’ Correspondence/Memorandum (refer to Attachment C), ambient air quality standards will be attained and maintained for TSP, PM 10 , PM 2.5 , SO 2 , NO 2 , and CO, and the PSD Class II increments will be protected for PM 10 , SO 2 , and NO 2

.

Location WE has its operations along a water contributory just south of La ke Wausau in the Village of Rothschild, Marathon County. The a rea is currently in attainment for all criteria pollu tants. PSD baselines in Marathon County for PM 10 and SO 2 were set in 1987, while the baseline for nitrogen oxides was established in 1993.

Modeling Analysis RTP Environmental Associates Inc.(RTP), consultant for WE, provided a complete modeling analysis as an appendix (“E”) to their permit application. Emissions rates along with other stack parame ters submitted with the analysis were verified against those supplied with the permit application by Steve Dunn (DNR). The input variables to the analysis including stack parameters, emission rates , and building dimensions were confirmed by J.R. Sims (DNR). Additionally, impact results were examined by J.R. Sims and found to be consistent with expectations.

Five years (1998-2002) of preprocessed meteor ological data was used in this analysis. The surface data was collected in Wausau, and the upper air meteorological data originated in Green Bay. This data was processed w ith AERMET, using the most representative l and

use data available.- 7 - The American Meteorological Society/Envi ronmental Protection Agency Regulatory Model Improvement Committee (AERMIC) steady-state plume model (AERMOD v 09292) was used in this analysis. The model used rural dispersion coefficients with regulato ry and non regulatory default options. These options allow for missing and calm wind correction, buoyancy induced dispersion, buil ding downwash, recirculation cavity effects and internal computing of Ozone limiting values.

Multiple grid configurations were considered and used, the larg est of which being a rectangular grid of 9,971 receptors centere d on the facility. Receptor spacing ranged from a minimum 25 meters to a ma ximum 1000 meters. The complete receptor grid consumed a tota l area of 514 million square meters (1.7 billion square feet). Terra in elevations were determined with AERMAP, using USGS Nationa l Elevation Dataset (NED).

Fugitive based particulate emissions, including total suspended particulate (TSP), PM 10 and PM 2.5 , from truck traffic onsite were included in the model as a volume source. The modeled emissions were subject to the following restrictions, which are permit

enforceable: there will be no truck traffic at WE Energies between the hours of 10 pm and 6am, and there will be no loading or unloading of transport vehicles at WE Energies between the hours of 10pm and 6am.

PSD Increment Analysis The proposed construction of WE Energies sources and modifications to existing Domtar sources were modeled to determine the are a of significant impact for the criteria pollutants, and it was discovered that concentrations for PM 10 , and 1-hour NO 2 were above significant impact levels, so an increment analysis was perform ed. Additional increment consuming sources, other than those at WE exist in the area. The maximum impact of all the increment consum ing sources has been considered for this analysis and will be shown to be below the PSD Class II increments for all pollutants.

NAAQS Analysis The maximum impact of all WE sources was considered for this analysis and will be shown to a ttain and maintain NAAQS for PM 10 , and 1-hour NO 2 , and will satisfy Wisconsin’s ambient air quality standard s for total suspended particulates (TSP). The regional background concentrations for the criteria pollutants were derived from several years of monitoring data.

Additional Impact Analysis

Soils and Vegetation Impacts

Since the modeled impacts from the modification are low, no vegetative impacts due to emissions from the project, or as a resul t of associated growth , are expected.

Visibility Impairment Analysis

Any facility emitting SO 2 , PM/PM 10 , and/or NO X may have a potential adverse impact on visibility through atmospheric discoloration or reduction of visual range due to increased haze. The Clean Air Act Amendments require evaluation of visibility impairment in the vicinity of PSD Class I area due to emissions from new or modi fied air pollution sources. Since there are no PSD Class I areas within 100 kilometers of the site, visibility impacts on distant Class I areas are negligible. ( Note: A Class I area is an area that is afforded additional protect under the Clean Air Act from the impacts of air pollution. National Parks, National Wilderness Areas and Nat ional Monuments are all designated as Class I areas.)

Near the proposed project site, under certain meteorological conditions, the stacks will emit a visible steam plume that, after traveling a relatively short distance, will dissipate by dispersion and eva poration. A visible steam plume can be expected to occur when ambient air temperatures are relatively low with respect to plume temper ature, thus promoting plume cooling and condensation, and ambie nt humidity levels are relatively high, preventing evaporation of the water in the plume. The persistence of the plume is dependen t upon wind speed and the time required for evaporation.

Conclusions Assuming the emission rates and stack parameters listed in Table 1 of the ‘Air Dispersion Analysis in support of a PSD Permit Application for WE Energies - Rothschild (Marathon County)’ Corr espondence/Memorandum (refer to Attachment C), the impact of the proposed modifications to WE will not violate PSD Class II increments or State or Federal ambient air quality standards as shown by the results in Tables 2a-c, and Figure 1 below.

WE may be permitted to modify their Rothschild facility so long as the information provided for this analysis remains unchanged and all conditions listed in the ‘Air Dispersion Analysis in support of a PSD Permit Application for WE Energies - Rothschild (Mara thon County)’ Correspondence/Memorandum (refer to Attachment C) are met.- 8 - Table 2a: Wisconsin Regional Background Concentrations

Wisconsin Regional Background

Concentrations (All Concentrations in μ g/m3)

Pollutant Period Value

TSP 24 hour 39.7

PM 10 24 hour 29.4

PM 2.5 24 hour

Annual 25.6

8.7 Pb Quarterly 0.01

NO 2 1 hour 60.0

CO 1 hour

8 hour 950.5

904.7

Table 2b: Significant Impact Analysis

SIL Analysis Results (All Concentrations in μ g/m3)

PM 10 24 hour PM 10 Annual PM 2.5 24 hour PM 2.5 Annual Project Impact (1st High) 15.7 3.0 2.8 0.6

Sig. Impact

Level 5.0 1.0 1.2 0.3

SIL Analysis Results (All Concentrations in μ g/m3)

SO 2 1 hour SO 2 3 hour SO 2 24 hour SO 2 Annual Project Impact (1st High) 7.3 5.9 1.3 0.1

Sig. Impact

Level 7.8 25.0 5.0 1.0- 9 - SIL Analysis Results (All Concentrations in μ g/m3)

NO 2 1 hour NO 2 Annual CO
1 hour CO
8 hour Project Impact (1st High) 48.0 0.6 770.0 404.0

Sig. Impact

Level 7.5 1.0 2000.0 500.0

Note: NO 2 conversion is based on the Plume Volume Molar Ratio Method (PVMRM). Modeling results show concentra tions that exceed the significant impact level for the following pollutants and averaging times, 24
hour and annual PM 2.5 , PM 10 and 1-hour NO 2 . An analysis comparing impact of the following pollutants against the NAAQS is required: 1-hour NO 2 , 24 hour and annual PM 2.5 , 24 hour PM 10

. An analysis comparing impact of the following pollutants against the PSD class II increment standa rd is required: 24 hour and a nnual

PM 10

. An analysis comparing impact of the following pollutant ag ainst the Wisconsin standard is required: 24 hour TSP.

Table 2c: Increment and NAAQS Analysis

NAAQS Analysis PM 10 24 hour
Facility Impact 39.1 Background 29.4

Total 68.5
NAAQS 150.0 % of NAAQS 46

NAAQS Analysis NO 2 1 hour

Facility Impact 58
Background 60

Total 118.0
NAAQS 188.0 % of NAAQS 63

Increment Analysis PM 10 24 hour PM 10 Annual
All Increment Consuming Devices 15.8 3.2

PSD Class II Increment 30.0 17.0

% Increment Consumed 53 19

NAAQS Analysis Pb

24 hour
Facility Impact 0.0005 Background 0.01

Total 0.0105
NAAQS 0.15 % of NAAQS 7- 10 - NAAQS Analysis TSP
24 hour
Facility Impact 100.6 Background 39.7

Total 140.3
NAAQS 150.0 % of NAAQS 94

NAAQS Analysis PM 2.5 24 hour PM 2.5 Annual
Facility Impact 7.8 1.6 Background 25.6 8.7

Total 33.4 10.3
NAAQS 35.0 15.0 % of NAAQS 95 69- 11 -Figure 1: 24 Hour Particulate Matter Gradient0 100 200 30050MetersModeled Concentration GradientWe Energies - Rothschild Biomass Project- modeled impact includes emissions from We Energies Rothschild, Domtar, and Lignotech- background concentrations not includedThe data shown on this maphave been obtained from varioussources, and are of varying age,reliability, and resolution. Thismap is not an authoritativesource of information aboutambient air quality orair emission sources.January 2011Concentration Legend< 3031 - 5051 - 7071 - 9091 - 111(μg/m )3- 12 - B.2.2. Ambient Air Dispersion Modeling for Sp ecific Receptors, and Air Quality Index Review

Introduction This analysis examines the short term pollutant impact at discr eet locations due to the operations of WE Energies. For this ana lysis 24 hour TSP emission rates were used and compared against 24 hour PM 10 standards. It is the opinion of WDNR that measuring the higher emission loading due to TSP agai nst the more restrictive standard of PM 10 on a short term basis (24 hour) represents an unusually dramatic worst case scenario. Ad ditionally, this analysis focu ses on the highest impact found at each receptor; again this scenario represents an unusually dramatic worst case. The protocol of this analysis exceeds current WDNR modeling guidelines an d its conclusions and results are overly conservative.

Location WE is located at 200 Grand Avenue, Village of Rothschild, Marat hon County, Wisconsin. The area is currently in attainment for all criteria pollutants.

Modeling Analysis RTP Environmental Associates Inc.(RTP), consultant for WE, provided a complete modeling analysis as an appendix (“E”) to their permit application. Emissions rates along with other stack paramete rs submitted with the analysis were verified against those s upplied with the permit application by Steve Dunn. The input variables to the analysis including stack parameters, emission rates, and building dimensions were confirmed by J.R. Sims. Additionally, impact results were examined by J.R. Sims and found to be consistent with expectations.

Five years (1998-2002) of preprocessed meteor ological data was used in this analysis. The surface data was collected in Wausau, and the upper air meteorological data originated in Green Bay. This data was processed w ith AERMET, using the most representative l and

use data available.

The American Meteorological Society/Envi ronmental Protection Agency Regulatory Model Improvement Committee (AERMIC) steady-state plume model (AERMOD v 09292) was used in this analysis. The model used rural dispersion coefficients with regulato ry and non regulatory default options. These options allow for missing and calm wind correction, buoyancy induced dispersion, buil ding downwash and recirculation cavity effects.

A single grid consisting of 5 receptors pl aced at locations deemed to be sensitive wa s used for this analysis. Terrain elevatio ns were determined with AERMAP, using USGS National Elevation Dataset (NED).

Fugitive based particulate emissions from truck traffic onsite we re included in the model as a volume source. The modeled emiss ions were subject to the following restrictions , which are permit enforceable: there will be no truck traffic at WE Energies between the hours of 10 pm and 6am, and there will be no loading or unloading of transport vehicles at WE En ergies between the hours of 10p m and 6am.

NAAQS Analysis The maximum impact of all WE sources was considered for this analysis and will satisfy Wisconsin’s ambient air quality standard s for total suspended particulates (TSP). The regional background conc entrations for the criteria pollutants were derived from severa l years of monitoring data.

Conclusions The impact of the proposed modifications to WE will not violate State or Federal ambient air quality standards as shown by the results in Table 3 of this document. WE may be permitted to modify th eir Rothschild facility so long as the information provided for th is analysis remains unchanged and all conditions are met.- 13 - Table 3: Increment and NAAQS Analysis

Location of Receptor Facility Impact Facility Impact + Background Alpha 292597 4973673 46.9 86.6

Beta 293276 4974303 16.3 56.0

Gamma 295217 4974751 3.9 43.6

Delta 294248 4975101 6.4 46.1 Epsilon 293524 4975375 20.7 60.4

Wisconsin Regional Background

Concentrations

Pollutant Period Value

TSP 24 hour 39.7

All Concentrations in μ g/m 3- 14 -Figure 2: Modeled Concentrations at Discrete ReceptorsBetaDeltaGammaAlphaEpsilon0 500250MetersModeled Concentration at Discrete ReceptorsWe Energies - Rothschild Biomass Project- modeled impact includes emissions from We Energies Rothschild, Domtar, and Lignotech- background concentrations not included- 24-hr standard is 150 ugThe data shown on this maphave been obtained from varioussources, and are of varying age,reliability, and resolution. Thismap is not an authoritativesource of information aboutambient air quality orair emission sources.January 2011Facility ImpactFacility Boundary- 15 - The following table displays the pollutant impact due to the pro posed increase in operation at WE Energies. The table shows the name of the pollutant, the type of pollutant being calculated, the impact or amount of that pollutant and the relative healthiness o f the air. This impact is the average level of pollutant we would expect to measure at a particular location by using an air sampling moni tor. The relative healthiness of the air is measured by what is called the Air Quality Index (AQI).

The AQI is an index for reporting daily ai r quality. It tells you how clean or polluted your air is. For the purpose of this an alysis, the reported AQI is a hypothetical value, because the listed impact is a forecast and as such has no t actually been measured in the field. The listing of the AQI is intended to help the reader understand the level of health risk associated with the listed impact.

Table 4: Air Quality Index Analysis

Air Quality Index Analysis (All Concentrations in μ g/m3)

24 hour PM 10 (small particles) 24 hour PM 2.5 (very small particles) 8 hour CO 24 hour SO 2
Project Impact (1st High) 15.7 2.8 404 1.3

Background 29.4 25.6 904.7 11.2

Total 45.1 28.4 1308.7 12.5
AQI 42 83 0 0
Air Quality GOOD Moderate GOOD GOOD

This Air quality index analysis tells you what we expect the quality of the air to be on the very worst day that we could find. The scale

reads:

The results of the modeling analysis demonstrate that the prim ary standard for the listed pollutants will be met provided the e missions rates, stack parameters and all other restrictions used in this analysis do not change. Therefor e, the health of "sensitive" po pulations such as asthmatics, children, and the elderly will be protected. Additionally, the welfare of the public is also protected, inc luding protection against decreased visibility, damage to animals, crops, vegetation, and buildings.

B.2.3. Inhalation Risk and Non- Carcinogenic Effects Screening for Ha zardous Air Pollutant Emissions

Introduction The upper bound inhalation cancer risk from hazardous air pollutant (HAP) emissions has been determined for WE Energies project

. The emission rates of all HAPs listed in table 4a are the potentia l emissions as determined by the Department for the facility. The emission limits in pounds per hour as listed in table 5a result in a potential maximum inhalation risk and/or non-carcinogenic impact as shown in table 5b. This maximum inhalation risk is equal to or greater than the highest expected residential risk based on p otential emissions. The non-carcinogenic impact is equal to or greater th an the highest expected impact at the receptor based on potenti al emissions. The only route of exposure considered for risk was inhalation and the modeled hours of operation were 24 hours/day, 365 days/year (8,760 hrs/yr).

Analysis
The inhalation risk factors were obtained from USEPA via the Inte grated Risk Information System (IRIS) web site or the Californ ia Air Resource Board (CARB). Table 5b lists the modeled high concentration and inhalation risk as determined by the department fo r the receptors indicated. The inhalation risk was obtained by mu ltiplying the receptor concentra tion by the risk factors.

The USEPA Class or "Weight of Evidence" criteria are a rating of the various hazardous substances describing how well establish ed- 16 - the risks are. Those classified as "A" are known human carcino gens. Those classified as "B" are suspected human carcinogens.

Toxicological Assumptions Health and Environmental Analyses require the use of assumptions to predict the impacts of any proposed action. It is therefor e important to include the assumptions used in the analysis.

a. For cancer risk analysis, the assumptions us ed are that a person weighing 70 kilogram s lives at the point of maximum impact for 70 years and breathes 20 m 3 of air per day. When human data on carcinogeni city of a chemical are available, those data are preferred. However, those data often have to be extrapolated from occupational, or other higher exposure levels, to lower exposure levels and additional assumptions must be made. Another assumption is that when human data is unavailable, animal data for carcinogens can be extrapolated to humans and that the higher doses used in animal studies can be extrapolated to lowe r doses that are typical of human exposures. In addition, it is a ssumed that cancer is a non-threshold process, and even a very small amount of a cancer agent has some level of risk associated with it (i.e. even if one molecule of the chemical is present, there is some risk, however small it may be).

b. The risk estimated in this analysis represents the highest lik ely (or 95% upper bound) risk under the assumed conditions. The actual risk (using the assumptions) could be lower and even approach zero, but because the way the mathematical models work, there is no way of telling what the actual risk is. It can only be stated that the "true risk " is between zero and the upper b ound

value estimated in the mathematical model.

c. This analysis did not consider other chemicals and other routes of exposure. Depending on what other chemicals are involved an d what the exposure scenarios are, actual total risk could be different.

d. The estimation of emissions from a facility and the modeling of ambient air impacts also have assumptions that must be considered in determining the likelihood that the risks represent actual risks.

e. There may be other chemicals of concern that were not addressed or of which we do not currently know. For this analysis, other contaminants contained in Table A of NR 445, Wisconsin Administrative Code, were excluded if their emissions were estimated

to be below the de minimis emission rates in NR 445.

f. Non-cancer risks were addressed in this analysis.

g. Environmental risks were not addressed in this analysis.

h. Background levels and multiple sources of the pollutants were not addressed.

i. All risks were considered to be additive.

Table 5a: Hazardous Air Pollutant Emission Rates

Contaminant Emission Rate (pounds per hour)

Antimony 0.006

Arsenic 0.018 Beryllium 0.001

Cadmium 0.003

Chromium 0.017
Chromium,-hexavalent 0.003

Cobalt 0.005

Lead 0.038 Manganese 1.28

Nickel 0.026 Phosphorus 0.022

Selenium 0.002 Hydrogen-chloride 14.4 Hydrogen-fluoride 0.8 Acetaldehyde 0.664

Acrolein 0.0601

Benzene 3.36 Benzo(a)anthracene 0.000052 Benzo(b)fluoranthene 0.00008 Benzo(e)pyrene 0.000002 Benzo(g,h,i)perylene 0.000074 Benzo(j,k)fluoranthene 0.000128- 17 - Contaminant Emission Rate (pounds per hour)
Benzo(k)fluoranthene 0.000029 bis(2-Ethylhexyl)phthalate 0.000038

Bromomethane 0.012

2-Butanone 0.004

Carbon-tetrachloride 0.036

Chlorine 0.632

Chlorobenzene 0.026

Chloroform 0.022

Chloromethane 0.018
1,2-Dibromoethene 0.044 Total-Polychlorinated-biphenyls-(PCB) 0.000006 Total-Equiv.-2,3,7,8-TCDD-(Dioxins) 0.000002 1,2-Dichloroethane-(EDC) 0.023

Dichloromethane 0.232 1,2-Dichloropropane 0.026 Ethyl-benzene 0.025 Formaldehyde 3.52 Indeno(1,2,3,c,d)pyrene 0.0000696 2-Methylnaphthalene 0.000128 Naphthalene 0.078 4-Nitrophenol 0.000088 Pentachlorophenol-(PCP) 0.0000408

Phenol 0.041 Propanal-(Propionaldehyde) 0.003 Propionaldehyde 0.049 Styrene 1.52 Tetrachloroethene-(Perchloroethylene) 0.03

Toluene 0.736
1,1,1-Trichloroethane 0.025

Trichloroethene 0.024 Trichlorofluoromethane-(CFC?11) 0.033 Vinyl-Chloride 0.014 o-Xylene 0.02 Mercury 0.002- 18 -Table 5b: Potential Maximum InhalationRisk and/or Non-carcinogenic ImpactContaminantEmissionRate(poundsper hour)AnnualImpact1 HourImpact24 HourImpactRiskFactorRiskStandardStandardPeriodRiskPeriodAntimony 6.00E-03 2.42E-05 12 24 hourArsenic 1.80E-02 4.32E-06 4.30E-03 1.86E-08 AnnualBeryllium 1.00E-03 2.40E-07 1.40E-03 3.36E-10 0.02 Annual AnnualCadmium 3.00E-03 7.20E-07 1.80E-03 1.30E-09Chromium 1.70E-02 4.08E-06 6.85E-05 1.20E-02 4.90E-08 12 Annual 24 hourChromium,-hexavalent 3.00E-03 7.20E-07 6.85E-05 1.21E-05Cobalt 5.00E-03 2.02E-05 0.48 24 hourLead 3.80E-02 9.12E-06 8.68E-04 1.53E-04Manganese 1.28E+00 5.16E-03 1.8 24 hourNickel 2.60E-02 6.24E-06 2.60E-04 1.62E-09 AnnualPhosphorus 2.20E-02 8.87E-05 2.43 24 hourSelenium 2.00E-03 8.06E-06 4.8 24 hourHydrogen-chloride 1.44E+01 3.46E-03 3.29E-01 746/20 1 hour/AnnualHydrogen-fluoride 8.00E-01 1.83E-02 246 1 hourAcetaldehyde 6.64E-01 1.59E-04 1.52E-02 2.20E-06 3.51E-10 4505 Annual 1 hourAcrolein 6.01E-02 1.37E-03 22.9 1 hourBenzene 3.36E+00 8.06E-04 7.80E-06 6.29E-09 AnnualBenzo(a)anthracene 5.20E-05 1.25E-08 1.19E-06 2.10E-07Benzo(a)pyrene 2.08E-03 4.99E-07 1.10E-03 5.49E-10 AnnualBenzo(b)fluoranthene 8.00E-05 1.92E-08 1.10E-04 2.11E-12 AnnualBenzo(e)pyrene 2.00E-06 4.80E-10 4.57E-08 8.06E-09Benzo(g,h,i)perylene 7.40E-05 1.78E-08 1.69E-06 2.98E-07Benzo(j,k)fluoranthene 1.28E-04 3.07E-08 2.92E-06 5.16E-07Benzo(k)fluoranthene 2.90E-05 6.96E-09 1.10E-04 7.66E-13 Annualbis(2-Ethylhexyl)phthalate 3.80E-05 9.12E-09 8.68E-07 1.53E-07Bromomethane 1.20E-02 2.88E-06 4.84E-05 93.2/5 24 hr/Annual2-Butanone 4.00E-03 9.60E-07 9.14E-05 1.61E-05Carbon-tetrachloride 3.60E-02 8.64E-06 1.50E-05 1.30E-10 AnnualChlorine 6.32E-01 2.55E-03 34.8 24 hourChlorobenzene 2.60E-02 1.05E-04 1105 24 hourChloroform 2.20E-02 5.28E-06 8.87E-05 5.30E-06 2.80E-11 1172 Annual 24 hourChloromethane 1.80E-02 7.25E-05 2478 24 hour- 19 -ContaminantEmissionRate(poundsper hour)AnnualImpact1 HourImpact24 HourImpactRiskFactorRiskStandardStandardPeriodRiskPeriod1,2-Dibromoethene 4.40E-02 1.06E-05 1.00E-03 1.77E-04Total-Polychlorinated-biphenyls-(PCB) 6.00E-06 1.44E-09 1.37E-07 2.42E-08Total-Equiv.-2,3,7,8-TCDD-(Dioxins) 2.00E-06 4.80E-10 3.30E+01 1.58E-08 Annual Annual1,2-Dichloroethane-(EDC) 2.30E-02 5.52E-06 9.27E-05 2.60E-05 1.44E-10 971 Annual 24 hourDichloromethane 2.32E-01 5.57E-05 9.35E-04 4.70E-07 2.62E-11 4168 Annual 24 hour1,2-Dichloropropane 2.60E-02 6.24E-06 1.05E-04 8318/4 24 hr/AnnualEthyl-benzene 2.50E-02 6.00E-06 1.01E-04 10421/1000 24 hr/AnnualFormaldehyde 3.52E+00 8.45E-04 1.30E-05 1.10E-08 AnnualIndeno(1,2,3,c,d)pyrene 6.96E-05 1.67E-08 1.59E-06 2.80E-072-Methylnaphthalene 1.28E-04 3.07E-08 2.92E-06 5.16E-07Naphthalene 7.80E-02 3.14E-04 1258 24 hour4-Nitrophenol 8.80E-05 2.11E-08 2.01E-06 3.55E-07Pentachlorophenol-(PCP) 4.08E-05 1.64E-07 12 24 hourPhenol 4.10E-02 1.65E-04 462 24 hourPropanal-(Propionaldehyde) 3.00E-03 7.20E-07 6.85E-05 1.21E-05Propionaldehyde 4.90E-02 1.18E-05 1.12E-03 1.97E-04Styrene 1.52E+00 3.65E-04 3.47E-02 6.13E-03Tetrachloroethene-(Perchloroethylene) 3.00E-02 7.20E-06 1.21E-04 5.90E-06 4.25E-11 4069 Annual 24 hourToluene 7.36E-01 1.77E-04 2.97E-03 4522/400 24 hr/Annual1,1,1-Trichloroethane 2.50E-02 6.00E-06 5.71E-04 1.01E-04Trichloroethene 2.40E-02 5.76E-06 9.67E-05 2.00E-06 1.15E-11 6449 Annual 24 hourTrichlorofluoromethane-(CFC?11) 3.30E-02 7.92E-06 7.54E-04 1.33E-04Vinyl-Chloride 1.40E-02 3.36E-06 8.80E-06 2.96E-11 100 Annual Annualo-Xylene 2.00E-02 4.80E-06 4.57E-04 8.06E-05Mercury 2.00E-03 8.06E-06 0.24 24 hourNote: An annual, 1-hour or 24-hour impact is calculated when there is a corresponding standard and standard period available. Alevel of risk is calculated when there is acorresponding riskfactor available.- 20 - Conclusions Air quality impacts from hazardous ai r contaminants at the maximum point of impact and at sensitive receptors are expected to b e low compared to existing state health based standards for acute an d chronic non-carcinogenetic and carcinogenetic compounds.

C. Cumulative Impacts

PSC’s EA, section 5.8, briefly considers cumulative air impacts, including those generated by the project in addition to those from the nearby local industries. DNR’s independent review of cumulative air impacts from stationary sources included analyzing ambient air impacts of emissions from Domtar, Lignotec h, and WPSC-Weston, in addition to the proposed facility. Refer to the Ambient Air Dispersion Modeling and Risk Analysis sections above for more in formation. Based on the review conducted, the Department finds that the cumulative impacts from all sources considered result in attainment of all ambient air quality standards when the sour ces operate in compliance with their existing or proposed air pollution control permits.

D. Conclusion for Air Impacts

Air quality impacts are expected to be w ithin acceptable and permittable standards. The Department will require enforceable operational controls as permit conditions, in addition to air emission monitoring equipment and protocol to monitor compliance – see draft permit, Attachment C. Based on DNR’s analysis and consid ering enforceable permit requirements the proposed action is expected to achieve compliance with applicable air quality sta ndards and regulations and maintain Marathon County’s designation as an air quality attainment area.- 21 - Amended Project Name: Wisconsin Electric Power Company Application for Air Pollution Control Permits for Construction and Operation of a 50 Megawatt Biomass-Fueled Cogeneration Facility County: Marathon

DECISION (This decision is not final until certified by the appropriate authority)

In accordance with s. 1.11, Stats., and Ch. NR 150, Adm. Code, the Department is authorized and required to determine whether i t has complied with s. 1.11, Stats., and Ch. NR 150, Wis. Adm. Code.

Complete either A or B below:

A. EIS Process Not Required

The attached analysis of the expected impacts of this proposal is of sufficient scope and detail to conclude that this is not a major action which would significantly affect the quality of the human environment. In my opinion, therefore, an environmental impact statement i s not required prior to final action by the Department.

B. Major Action Requiring the Full EIS Process

The proposal is of such magnitude and complexity with such considerable and important impacts on the quality of the human envir onment that it constitutes a major action si gnificantly affecting the quality of the human environment.

Signature of Evaluator Date Signed

Number of responses to news release or other notice (if provided):

Certified to be in compliance with WEPA Environmental Analysis and Liaison Program Staff Date Signed

NOTICE OF APPEAL RIGHTS

If you believe that you have a right to c hallenge this decision, you should know that the Wisconsin statutes and administrative rules establish time periods within which requests to review Depa rtment decisions must be filed. For judi cial review of a decision pursuant to sect ions 227.52 and 227.53, Wis. Stats., you have 30 days after the decision is mailed, or ot herwise served by the Department, to file your petition with t he appropriate circuit court and serve the petition on the Department. Such a petition for judici al review must name the Department of Natural Resources as the respondent.

To request a contested case hearing pursuant to section 227.42, Wi s. Stats., you have 30 days after the decision is mailed, or otherwise served by the Department, to serve a petition for hearing on the Secretary of t he Department of Natural Resources. All requests for contested case hearings must be made in accordance with section NR 2.05(5), Wis. Adm. Code, and served on the Secretary in accordance with section NR 2.03, Wis . Adm. Code. The filing of a request for a contested case hearing does not extend the 30 day period for filing a petition for judicial review.- 22 - 

### Attachment A

Domtar/WEPCO Biomass Generating Facility Air Permit January, 2011 Identified Public Issues/Concerns and DNR Responses

(Note: In addition to text provided in DNR’s EA amendment, ad ditional information related to listed issues/responses is provide d in PSC’s EA for this project, see Attachment B)

1. If I understand correctly, there are NO particulate matter monitors in Marathon County. We need PM monitors now, especially for the elementary school across the st reet from the proposed plant.

DNR Response:

The Department does not operate a particle monitor in Marathon County. Federal air monitoring requirements do not call for part icle monitoring in Marathon County.

Based on the Department’s review of the proposed project (see Preliminary Determination for permit 10-SDD-058), along with determinations made for other local industry’s air pollution control permits including the cumulative ambient air impact analys is from all these sources, we do not expect any exceedence of the na tional ambient air quality standards set forth to protect public he alth and welfare [ch. NR 404, Wis. Adm. Code]. Th erefore the Department concludes that there is no need for any additional monitors for particulate matter, or any other air contaminan t, for the local area within Marathon County.

2. When the pollution from the WE Energi es facility is added to the background pollu tion, the particulate matter will be at 99 % in a 24 hour period. However, the diesel emissions from the 35,750 semi trucks coming in and out each year are not counted in the particulate matter- due to a loophole. (500,000 tons of wood burned a year, divided by 28 tons the amount each truck can carry ). If the semi truck emissions could be added in to the local effect and level of particulate matter, then the background and new pla nt emissions would be over the 99% standard of what the NAAQS says is safe.

Domtar and WE Energies may not have to report the emissions, but for the kids on the playground the emissions will be a reality and according to the EPA they will have deleterious health effects on the children, and community.

DNR Response:

Diesel exhaust emissions off-site are not re gulated by the proposed stationary source air pollution control permit. While emiss ions from diesel exhaust specific to this facility/project are not di rectly included in an air quality dispersion modeling analysis, they are indirectly through inclusion of background. Diesel exhaust (mob ile source) emissions are included in the air quality dispersion model only as part of the background concentrations, which is added to the total impact from the stationary source emission impacts a nd do show attainment of the ambient air quality standards.

3. I do not understand how going from burning 50,000 tons of wood to burning 500,000 tons of wood will make the air 30% cleane r? They are not hauling out 500,000 tons of fly and bottom ash. In fact I think the number is more like 18,000 tons. Where does the rest go? When we ask what the specific emissions will be at 40%, 80% and 100% they say "it will be 30% cleaner" What are the specif ic

emissions?

DNR Response:

The specific emission rates from the propose d project are included in the preliminary determination document for air pollution control construction permit 10-SDD-058, and under section B.1. of this EA. A ‘30%’ cleaner factor can be explained by looking at the emission values used in the comparison. Based on the proposed project, there are several existin g combustion units at Domtar th at will be shut down upon start-up of the new WE Energies biomass boile r. Furthermore, the new biomass boiler will be of newer technolo gy, operating at greater effici encies with better emission controls, more stringent regulatory and operational limitations. When co mparing

the current actual emissions from the exis ting facility operations to those of the future actual (anticipated actual operationa l) emissions of the new facility (WE Energies) and then remaining operationa l unit emissions (Domtar), a reduction in the overall emissions can be

achieved.

The comparison can be calculated from Table 3 of the PSC EA, replicated and explained below.

PSC EA: Table 3: Current air pollutant emission rates at the Rothschild Domtar mill and WEPCO’s expected emission rates if- 23 - proposed CFB project is approved, in tons per year.

Pollutant Current Domtar Actual Emission Rate (tons per year) 34 Expected WEPCO CFB Actual Emission Rate (tons per year) 35

NOx 396 172

CO 230 218

SO2 1.4 5

Particulate

Matter 20 46

VOCs 16 16

TOTAL 663.4 457

34 – Data from WEPCO project application, page 54, Table 2.18-1.

35 – Information from WEPCO project application, Section 2.18, page 54, Table 2.18-2.

30% cleaner air can be calculated from the total amount of emissions from all pollutants under each scenario: (663.4 tons per year) x (1 – 0.30) = 464.4 tons per year

The reduced amount of air pollution (464.4 tons per year) is near to the expected new emissions (457 tons per year); approximat ely a
30% reduction.

Please also see response to comment #4 below for more information.

There’s an expected generated volume of 20,000 tons/year of solid waste, consisting of bottom ash and fly ash. Waste streams wi ll be handled separately. To the extent possible ash material will be beneficially reused for agricultural soil conditioner or re-bur ned at other facilities. If not beneficially reused ash wa ste is planned to be disposed of at Ma rathon County Landfill, which currently acce pts ash from Domtar. The county landfill’s monofill for ash disposal is cu rrently nearing capacity but the county is in the planning pr ocess for landfill expansion. The county has indicated if wood ash from the new facility is similar to Domtar’s existing wood ash, it wo uld be accepted at the landfill. The county landfill is licensed by DNR and has no outstandin g enforcement issues.

4. According to their application, they state once the plant is built, they will have 30% cleaner air. However, they also sta te when the plant pollution and the back ground pollution are added together, they will be at 99% of what is safe in a 24 hour period, accor ding to the NAAQS. What I do not understand is either they are not te lling the truth, or they are telling the truth and today, and eve ryday leading up to today, they have been in violation of the NAAQS. If they need the new plant to create 30% cleaner air, but it wi ll still put them at 99% of what is safe according to the NAAQS, where are they at now? What are the emissions at now?

DNR Response:

Current emissions from the proposed site are included under air pollution control permit 737010450-P10, which is the current enforceable air permit for Domtar Paper Company in Rothschild. Based on the air quality review for that permit (contained in th e preliminary determination for that permit action), the current impacts are as follows (% of NAAQS): Total Suspended Particulates (TSP): 98.2%

PM 10 , 24-hr: 74.7%

PM 10 , Annual: 48.0%

SO 2 , 3-hr: 64.6%

SO 2 , 24-hr: 83.8%

SO 2 , Annual: 98.6% Note: impacts also included nearby sources that ma y have potentially added impact around Domtar.

The following table represents the current potential (allowable) emissions from the Domtar facility (information from the preli minary determination document of permit 737010450-P10):

Pollutant Potential to Emit (TPY)

Particulate Matter Emissions 393.17

Carbon Monoxide 502.75

Nitrogen oxides 958.59- 24 - Pollutant Potential to Emit (TPY)

Volatile Organic Compounds 244.19

Sulfur Dioxide 300.21

The specific emission rates from the propose d project are included in the preliminary determination document for air pollution control construction permit 10-SDD-058, and under section B.1. of this EA. A ‘30%’ cleaner factor can be explained by looking at the emission values used in the comparison, please see the response to comment #3 above for more information.

While a ‘30%’ cleaner air factor could be explained by the difference in emissions, th at analysis uses future actual emissions from the proposed project. An air dispersion modeling analysis does not use actual emissions, but rather the potential (allowable) emiss ions that would be included in the air pollution control permit, which are typically much greater than th e actual emissions. Dispersion m odeling incorporates information about a facility, su ch as source/stack parameters, facility la yout information, and emission rates, al ong with 5 years of meteorological data, in order to predict concentrations of pollutants in the vicinity of the facility. The point of hi ghest impact is determined through the use of a receptor grid that is set up by the modeler, and could be the result of (besides other facto rs) inversions. The pollutant concentration at the point of highest im pact is added to a previously determined bac kground concentra tion and then is compared to the corresponding ambient air quality standard.

Therefore, the air dispersion analysis conducted for the existing operations (Domtar) could show one level of impact, while the air dispersion analysis conducted for the future operations (Domtar and WE Energies) would show a different level of impact, yet st ill be similar in the resulting level of that impact. This is apparent by the facility layout, source/stack parameters, operational li mitations and emission rates, which differ between the existing site operations and the future (proposed) site operations.

In summary, the ‘30%’ cleaner air statemen t has no reflection on the ambient air quality modeling analysis, but rather only a comparison in the current emissions from Domtar and the future actual emissions from WE Energies and Domtar. The ambient air quality analysis (dispersion model) always looks at the maximum potential (allowable) emissions from a proposed project, which would include any additional sources/facilities that may cumulatively affect the local impact.

5. What will the effects of the inverse air flow be? Today it is raining, and the air is moving down, the pollution coming ou t of the plant is lingering on the lot and in the community. Furthermore, we had air quality reports this year, when the air was stagna nt, and like today, the pollution did not dissipate. How is justifiable to expose a elementary school acr oss the street from the plant to all this pollution? How is it justifiable to expose a community to all th is pollution? When it rains, the air is stagnant, or there is inverse air flow, the air will linger in th e immediate community.

DNR Response:

Please refer to the ‘Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis’ section of the EA above for information regarding this issue.

6. We have heard the plant up north is a 20 megawatt plant that burns 250,000 tons of wood. This is a 50 megawatt, are they l isting 500,000 tons of wood being burned as th e amount because it places them under the NAAQS standards for air quality. If they will burn more, they will produce more pollution, and they will be over the NAAQS standard for air safety? Furthermore, at a school boa rd meeting they were asked if the wood inside would be a fire hazard? Terry Charles st ated it would not be because the wood is go ing to be moist. However, moist wood burns with less efficiency and th ey will need more wood to create the power they need. Is this figured into the amount of wood they will bu rn? They state the wood ch ips will be 45% water, which will be less efficient. Th ey state they will not sample every load, but for the safety of the community they should, due to the level of pollution they are operat ing at compared to the NAAQS.

DNR Response:

The air quality analysis (air dispersion modeling) uses the worse-case maximum potential emissions from the facility. Those emi ssions are based on several factors, including: fuel type and characteristics, emission factors, operational design and control equipm ent, and any enforceable operational and/or emission limitations. The cond itions that demonstrate compliance with the NAAQS will be set in the air pollution control permit as enforceab le emission limits, control device operatio ns, operational parameters (fuel type a nd amounts used), among other re quirements. Any future expansion or increase of production or combustion sought by the facility, a bove what may already be approved in a permit, may result in a new air pollution control permitting action, which would again analyz e all aspects of compliance with all air pollution rules and regulations.- 25 - The issue of fire hazards is outside the scope of the Air Program’s authority and review under this air pollution control permi t action.

7. I am learning more about the toxic effects of living near a landfill with power plant waste. Specifically, the higher rate of cancer for residents and the threat of ground water pollution. They state they will bump the fly ash and bottom ash in Ringle, WI. D o the residents know this? Has there been a study as far as the health effects of living near coal and biomass toxic ash dumps?

DNR Response:

Similar air pollution control permitting is reviewed for landf ills, including compliance with NAAQS. Specifically, the Marathon County Landfill currently has an air pollution control operation permit from the Department, permit #: 737092730-P03, and a mor e recent air pollution control construction perm it, permit #: 09-MHR-228. The preliminar y determination made for those permit act ions are available for review, and contain simila r review characteristics, including air qu ality analysis (air dispersion modeling), and municipal solid waste compliance for multiple air contaminants including volatile organic compounds and hazardous air pollutant s (both state and federal).

The existing ash monofill at Marathon County Landfill has an approv ed liner designed to prevent groundwater contamination. Any expansion would also be required to have a liner for the same purpose. Also refer to the response to comment #3 above for more

information about the landfill and tran sfer of the ash to that site.

8. Domtar and WE Energies have stated they will release dioxins and furans into the air from this plant. Is it justifiable to put this in

the air across the street from an elem entary school? Or a community?

DNR Response:

Emissions from the source have been shown to be in complian ce with all air pollution control permitting regulations, when opera ted in compliance with the permit. Those emissions will meet standards se t to protect public health and welfare, including such pollut ants as dioxins/furans. Specifically, emissions of dioxins/furans will be regulated to a level of maximum achievable control technology (MACT), per the proposed federal rule 40 CFR Part 63, Subpart DDDDD, "National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial and Institutional Boilers and Process Heaters"; Vol. 75 Federal Register No. 107, pp

. 32006-32073; June 4, 2010. Complying with the MACT standard will satisfy compliance with the state hazardous air pollutant regulations found under ch. NR 445, Wis. Adm. Code.

9. We saw in the report that before the power plant is built, se mi trucks were hauling out some of the sludge waste from the p aper mill. However, in the new application, the trucks that used to haul out the sludge paper mill waste are no longer used. Will they burn the paper mill waste? How much paper mill sludge waste will they burn?

DNR Response:



### The air pollution control permit will allow the facility to co mbust only biomass or natural g as in boiler B01, and only natural gas in boiler B02. Biomass, as defined in the perm it, means a resource that derives energy from wood or plant material or residue, clean solid wood wast e and crops grown for use as a resource. Fuel sources may include the following and other qualifying clean biomass sources:

• 

### logging residue

• 

### discarded woody material from primary manufacturing facilities such as paper mills, sawmills, or chip mills

• 

### on-site pulp & paper wastewater treatment plant residue

• 

### leftover woody material from secondary manufactur ers such as door, window, cabinet manufacturers

• 

### woody biomass from municipality wood waste, tree services, and construction companies

• 

### clean solid wood waste from discarded wood packaging such as pallets/crating and from construction and

demolition activities

• 

### woody biomass plantations, energy crops and agricultural residues.
Biomass excludes edible portions of food crops, refuse deri ved fuel, treated wood, municipal solid waste, sewerage- 26 - 

### sludge, and animal waste.

Therefore, only on-site pulp and paper mill wastewater treatment residue will be permitted to be combusted. This will be a very small percentage of the total fuel input to the biomass boiler

10. With the amount of CO2 pro duced, and the amount of moisture they will releas e into the local air, 576,000 gallons a day, combined with the amount of NOx, VOC's and sunlight, are we at risk for ozone issues?

DNR Response:

There is no ambient standard specifically for VOC emissions. However there are ambien t standards for NOx. Ozone is a related ambient standard since VOC emissions are considered a precursor to ozone formation, but as of yet no model has been developed t hat can predict ozone concentrations based on VOC or NOx emissions from a source. The regulation of NOx and VOC emissions as currently drafted will li mit the amount of ozone formation, and it is expected that there would be no ri sk for ozone issues as a result of this project.

11. The amount of sulfur dioxide they pu t in the air will increase from 11.8 in th e background they will put in 951 for a comb ined 962.8 micrograms per cubic meter, which is 74% of what the NAAQ S says is safe, but this is right across the street from an elementary school and a community. That is a large amount of SO2 for children and a community to absorb. According to the EPA "Current scientific evidence links short-term exposures to SO2, ranging from 5 minutes to 24 hours, with an array of adverse respiratory effects including bronchoconstriction and increased asthma symptoms. These effects are particularly important for asthmatics at elevated ventilation rates (e.g., while exercising or playing.)

Studies also show a connection between short-term exposure and increased visits to emergency departments and hospital admission s for respiratory illnesses, particularly in at-risk populations including children, the elderly, and asthmatics." http://www.epa.gov/air/sulfurdioxide/health.html

DNR Response:

Please refer to the ‘Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis’ section of the EA above for information regarding this issue..

12. WE Energies paid Scott Madden to investigate and make a re port which said the facility should be built in 2, one by Upper Michigan and one by Western Wisconsin. Also, that to be cost effective the wood should come from within 50 miles. We Energies and Domtar state they will draw the wood from a 100 mile radius. Scott Madden re ported that this would add to the cost, forcin g the power plant to seek other options to burn. Scott Madden also spoke about the pressure on pallet companies, paper industry, pel let makers, counter top producers, and the supply and demand issues from burning 500,000 tons of wood. In fact, this pressure I ju st spoke about was one of the reasons the paper industry people out of Green Bay opposed a plant in Ashland I believe. They state d there was not enough wood available. Oh yeah, the proposed plant (end of comment sent to DNR)

DNR Response:

The points raised relate to woody biomass availability on a sustainable basis, which is the similar to the question asked in co mment #13 below. See response to comment #13.

13. Is this project sustainable? WE Energies and Domtar state they have looked into the availability of wood, and they feel i t is good. However, according to the DNR and the stat e lawmakers, a current assessment is not available and according to the clean energy bill

for the state it was recommended that our DNR have an assessment done to see how much is available.

DNR Response:

The identified anchor fuel is woody biomass in the form of tops and branches generated during logging operations. The applicant conducted several studies to determine possible options for fuel type, generation facility size and location, availability of f uel and estimated fuel and other costs. Additional studies were done to determine the distance range of an adequate supply of woody log ging residue biomass to support a 50 megawatt generation facility. St udies concluded there was sufficient woody biomass available wi thin 75 miles to support the proposed facility. The Department has re viewed those studies and does not disagree with these findings, but we have not done independent confirmation studies. DNR has no auth ority to regulate fuel supply, source or cost for utility or private- 27 - enterprise projects. These are left as project viability business decisions. Aside from timber production, the public and priva te woodlands in the anticipated biomass supply radius provide other important economic, social and environmental benefits. Example s are soil and watershed protection, wildlife habitat and ecological diversity, recreation and aesthetics. Less understood indire ct benefits, such as carbon sequestration and its relationship to climate ch ange, are also provided. According to PSC’s environmental assess ment for this project 70-75% of Domtar-bound harvests are from fede ral/state/county forests, tribal forests and private lands enroll ed in the state managed forest land (MFL) program. Management objectives/r equirements of these forest lands is designed to protect all fo rest values (i.e. such as those noted above) in a sustainable manner. WEPCO, using Domtar as its biomass procurement agent, has stat ed it would include contract requirements that all harvest derived fuels for this project would follow existing and future guidelines (i.e. Wisconsin Woody Biomass Harvesting Guidelines developed by the Wisconsin Council on Forestry and approved by DNR and Wisconsin Forest Management Guidelines are two of several su ch ‘guidelines’, see PSC EA, section 2.3 for other examples) developed to sustain multi-purpose woodland values. WEPCO and Domtar have had initial discussions with DNR on potential auditing/monitoring methods for current and future guidelines. As pointed out in comme nt 13 above and in PSC’s EA as well, additional research and monitoring would be useful to help mini mize the potential risk of woody biomass-fuel procurement impact s from this and future projects to protect forest/woodland values in a sustainable manner. To add emphasis to this point, the PS C EA also notes that the fuel-source radius for this project overlaps with that of other approved or planned woody biomass fueled en ergy generation facilities. Thus, while most (70-75%) of the intended fuel-source forest lands for the Rothschild facility have exis ting management programs in place consistent w ith sustainability concepts, there is an u nknown threshold point at which available wo ody biomass can provide fuel for these types of projects. Future business start-up decisions using woody biomass as fuel will likel y take this limited resource availability factor into account during pr oject feasibility planning. But future studies would also help identify limits at which timber harvests can occur without jeopardizing all forest values.

14. There are currently four coal fired plants in Weston, less than 1.5 miles away from the proposed biomass plant. How much pollution can one area take? How much pollution is safe? This is one of many reasons why we need a environmental impact statement done for this facility.

DNR Response:

Please refer to the ‘Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis’ section of the EA above for information regarding this issue.

15. When I ask Domtar and WE Energies how much CO2 will be rel eased, they tell me "we are not required to report this" I even sited the federal law about reporting green house emissions, Federal Law CFR 98.2, they still said "we do not have to tell you the amount of CO2 coming out"

DNR Response:

Please refer to the ‘Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis’ section of the EA above for information regarding this issue.

16. I asked Domtar and WE Energies for an air dispersal report to see where the particulate matter would be concentrated, but neither would give it to me. In fact Terry Charles from Domtar agreed to meet with me and reassure me about why this plant was safe an d he said he would explain the air dispersal report. However, when I met with him, he said "I have nothing for you", and " you need to go through the proper people to get that information." I live right across the street, I have a 8 month old. he agrees to meet w ith me and reassure me about the communities safety, and then tell me go ask someone else. This is a big red flag for trust.

DNR Response:

Please refer to the ‘Operational Impacts, Am bient Air Dispersion Modeling and Risk Anal ysis’ section of the EA above. That sect ion provides information on the air dispersion analysis, including site specific impacts.

17. Will this power plant make our community a "non attainment area"? Will the combined pollution from the four Weston Coal plants, the local industries, and the new power plant make us a non attainment area? What will this combined pollution effect have on our community?

DNR Response:

A change in classification for Marathon County from attainment to non-attainment is not expected with the addition of this powe r plant. Please refer to the ‘Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis’ section for more informatio n- 28 - regarding this issue.

18. How much water will be returned to the Wisconsin River after this plant goes in?

DNR Response:

Based on available information provided by Domtar and WE the maximum discharge to the river from the biomass plant will be abou t 380 gallons/minute (gpm) or 0.547 million gallons/day (gpd). During average operating conditions the combined biomass discharge s would be about 250 gpm or 0.360 mgd. Domtar’s current average discharge is 6.8 mgd, so the increase from the biomass discharge is about 5% greater over existing.

19. I saw on the Weston coal plant application that the "heated water" that is returned to the river has an effect all the way down to Half Moon Lake. WE Energies and Domtar ha ve stated they will release "heated water" th at is at a higher rate than what is curr ently being released into the river. What effect will this combined heated wate r have on the river?

DNR Response:

New administrative rules that establish wa ter quality standards for te mperature became effective Oc tober 1, 2010. Based on information provided by Domtar and WE Energies to date, it appear s that water quality-based efflue nt limits for temperature wil l not be necessary when the standards are applied to Domtar’s wastewater discharges either at current flow rates or when flow rates a re increased due to the operation of the WE Energies facility.

20. Domtar has stated that they have 18,000 gallons of aqueous ammonia and 22,000 gallons of sodium hydroxide. However, they state they have a "liaison officer" who is responsible for notif ying the local, state and federal officials of a spill. We hav e a volunteer fire department in our community, should a spill occur, they do not have a clear plan to let the residents know about evacuatio n or what the potential problems could be.

DNR Response:

Prevention of spills by using prop er equipment, construction and inspection for storage and handling of hazardous chemicals is governed by the Wisconsin Commercial Building Code. This code is enforced by the Wisconsin Department of Commerce’s Safety and Buildings Division, and local building ordinances. Contact James Smith, Program Manager at the Wisconsin Department of

Commerce at 608 266 0251 for more information.

The “Liaison Officer” is necessary because the Federal Emergenc y Planning and Community Right-t o-Know Act (EPCRA) requires facilities to report to the local community if they have certai n quantities of chemicals on hand. This law also requires facili ties work with the fire departments and local emergency responders on de veloping emergency response plans and to assure that there is adequate training and equipment available in case of an incident. Marathon County does have trained and equipped hazardous materials incident responders available.

Facilities in Marathon County subject to EPCRA are required by Fe deral Law to report to, submit and coordinate response plans w ith the Marathon County Local Emergency Planning Committee (LEPC). Contact Jerome Boettcher, Marathon County Emergency Management Director, at 715 261 1222 for more information on EPCRA and the Marathon County LEPC.

Persons responsible for hazardous substance spills are also requ ired to respond to minimize any harmful effects of the spill un der State law, Chapter 292.11 Wisconsin Statutes. This laws enables the DNR to take action if the responsible party is unable or unwill ing to

do so. This law also allows the DNR to re quire preventive measures if they are inadequate by issuing an Administrative Order.

DNR Wardens work directly with local emergency responders on sp ills. DNR can assist local responders, hire contractors to respo nd if necessary, and has a wo rking relationship with US EPA and other federal agencies should Federal assistance be required. Cont act Tom Kendzierski, WDNR West Central Region Spill Coordinator at 715 839 1604 for more information.

21. When I asked them what the deleterious health effects of pm 2.5 are, they stated "we believe the project will meet these, EPA and NAAQS, requirements" However, with the se mi trucks, with the wood that is about 1/2 water (45% moisture) and with the amount of wood needed to keep the power plant running at 88% which is wh ere they say they will operate, I feel there are too many questio ns to dismiss looking into an environmental impact statement. I hope you will reconsider your belief that "an EIS" is not necessary.

DNR Response:- 29 - Please refer to the ‘Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis’ section of the EA above for information regarding this issue, along with the responses to comments #2 - #4, and #6 above. Following standard procedures for an air permit application, DNR has prepared an EA, which will be fo llowed by a subsequent decision whether or not to prepare an EI S. As allowed per NR 150.20((2)(f)(2), Wis. Adm. Code, the DNR EA is an amendment to a comprehensive EA prepared by Public Service Commission for this project.

22. Our current air quality is poor. In 1999, per the EPA, Marathon County was ra ted among the worst 10% of all counties in t he United States in terms of sulfur dioxide emissions. (Side note: Since then Weston 4 has started up to add much more.)

We ranked among the dirtier 40% of all coun ties in the US in terms of an average i ndividual's added cancer risk from hazardous air pollutants.

Source: Scorecard.org

DNR Response:

Please refer to the ‘Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis’ section of the EA above for information regarding this issue, along with the responses to comments #2 - #4, and #6 above.

23. When I asked WE Energies and Domtar about the effects of diesel, about how it stays local and does not dissipate, I asked Domtar and WE Energies what effect will the fugitive emissions have on the children who are playing on the playground next to the road

. After three times asking that question, Brian Mathey from WE Energies responded by saying "No way to determine if the trucks w ill have an impact" The plant will be at 99% of what is safe, the moisture content will be at 45%, the semi truck emissions are not counted in the particulate matter, and WE Energies feels there is "no way to determine if the trucks will have an impact."

Please make WE Energies and Domtar conduct an Environmental Imp act Statement related to this proposed biomass facility. For th e children at the elementary school ac ross the street, for the community.

DNR Response:

Please refer to the ‘Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis’ section of the EA above for information regarding this issue, along with the responses to comments #2 - #4, and #6 above.

Following standard procedures for an air permit application, DNR will prepare an EA followed by a subsequent decision whether o r not to prepare an EIS. As allowed per NR 150.20((2)(f)(2), Wis. Adm. Code, the DNR EA is an amendment to a comprehensive EA prepared by Public Service Commission for this project.- 30 - Attachment B – Copy of final PSC EA, sections 2.2.1 and 2.2.1.1 – 2.2.1.5



## 2.2.1 Air emissions

This section addresses the status of the DNR air permit process at the time of PSC EA preparation and also addresses potential impacts due to greenhouse gases ( GHG) and truck emissions.

Note : DNR is preparing an EA before action on the air pol lution permit application is taken. The DNR EA could include more detailed or up-to-date air emissions information.

2.2.1.1 Criteria pollutants

Because of the adverse impacts of air pollu tant emissions on health, welfare, and the environment, federal and state laws are i mplemented to reduce emissions to levels that research has shown would pr otect the majority of individuals and reduce overall impacts on e cosystems. The U.S. Environmental Protection Agency (EPA) has establishe d National Ambient Air Quality Standards (NAAQS) to regulate the emissions of six “criteria” pollutants: carbon monoxide (CO), nitrogen oxides (NO

x ), ozone (O 3 ), lead, particulates (PM, PM 10 , PM 2.5 ), and sulfur dioxide (SO 2 ). The standards are based on EPA’s interpretations of h ealth impact research related to those pollutants. The NAAQS levels are set by EPA with the intent to protect not on ly the general population, but also so-called “susceptible populat ions,” individuals with asthma, young children, and the elderly. To ach ieve this level of protection, EPA requires that modeling for new facilities’ air pollution control permits be performed at the maxi mum allowable emission level that would be permitted. The re quired emission level for the modeling to obtain a permit would be a level that could never be realized in actual operation. The requ irement would assume that the boiler would operate every hour of the year at 102 percent of capacity at its maximum permitted emissions level. Five years of meteorology data would also be required for the model to evaluate worst-case meteorological conditions.

State air permits regulate the emissions of the six criteria pollutants and other classes of pollutants in Wisconsin. Some cri teria pollutants require a different approach than the othe rs. Ozone is generally controlled by c ontrolling the emission of nitrogen oxides (NO

x ) and volatile organic compounds (VOC) that react with NO

x to form O 3 . PM 2.5 particles are emitted directly and are formed chemically in the atmosphere, mostly from NO

x and SO 2 . Power plants do not generally emit large quantities of lead, but are notable emitters of several other criteria pollutants. Lead emissions do not appear to be an issue for this project.

For this project, greenhouse gas emissions will be considered in the permit review as well. Treatment of greenhouse gases is d iscussed

below in Section 2.2.1.4.

The criteria pollutants are controlled mostly by application of Best Available Control Technologies (BACT) that bring each poll utant’s level below a certain limited emission rate. The company has pr oposed control technologies, and DNR will approve or modify the m after doing its own modeling and analyses.

 For NO

x emission control, BACT appears to be the CFB itself plus selective non-catalytic reduction.

 For SO 2 , BACT appears to be the CFB plus the use of low sulfur biomass fuels.

 For PM and PM 10 , BACT would be a fabric filter baghouse and, for PM 2.5 from the boiler, BACT would be the baghouse with

felted filter media.

 For VOCs and for CO, BACT would be the CFB itself and good combustion practices.

The project requires air pollution control construction and operati on permits from DNR. DNR review of the air permit applicati ons is in process; this review will verify or alter expectations.

Note : Under Wis. Admin. Code NR 150, DNR must prepare an environmental assessment for an air pollution control permit where the potential for increased emissions of criter ia pollutants would be 100 tons or more per year after controls. DNR is preparing an EA before action on the ai r pollution permit application is taken. The DNR EA could include more detailed or up-to-date air emissions information.

WEPCO states that the operation of the new CFB boiler and retirem ent of the existing Domtar boile rs would result in a decrease in overall emissions by about 30 percent. It provides two ta bles in the project application Technical Support Document 1 that add up the measured tons per year of criteria pollutants emitted from Domta r’s existing boilers and the estimat ed tons per year expected f rom the CFB, showing a 30 percent decrease in overall pollutant tons per year while producing slightly more British thermal units (Btu) per hour.

1 Technical Support Document, p. 54, Tables 2.18-1 and 2.18-2.- 31 - After showing WEPCO’s expected maximum allowable emission limits with the expected BACT for the individual pollutants, 2 the Technical Support Document provides the highe st modeled air concentrations at any r eceptor that would result in Marathon County in micrograms per cubic meter. 3 These concentrations must be compared with EPA- defined “significant impact levels” (SIL) to see which pollutants must go through a NAAQS analysis.

Table 3 summarizes the changes in criteria pollutant emissions (excluding lead 4 ) predicted by WEPCO in the CA application Technical Support Document. As DNR review of the air pollution control permit proceeds, these values might change.

Table 3 Current air pollutant emission rates at the Rothsch ild Domtar mill and WEPCO’s expected rates if proposed CFB project is approved, in tons per year

Pollutant Current Domtar Actual Emission Rate (tons per year) 5 Expected WEPCO CFB Actual

Emission Rate 6 (tons per year) Estimated Maximum Allowable Emissions for Entire Proposed Project, Representing BACT 7
(tons per year)

NO

x 396 172 372

CO 230 218 766

SO 2 1.4 5 316

PM and PM 10 121

PM 2.5 20 46 93

VOCs 16 16 66

The SILs are defined by EPA in air concentrations of micrograms per cubic meter (g/m 3 ) for the pollutants over certain established averaging periods during which they have been shown to have effects. EPA-defined SILs currently exist for PM 10 , CO, SO 2 , and the

annual NO 2 NAAQS, again based on interpretations of hea lth impact research related to those pollu tants. It is EPA’s policy to exempt proposed pollution sources from conducting comp rehensive, multisource modeling if their estimated maximum ambient impacts for a given pollutant are less than the SIL. In practice, if the modeled ambient impacts from a proposed project are less than the r espective SIL, it is presumed that the project will not cause or significantly contribute to a PSD increment or NAAQS violation. For this rea son, the project applicant would not be required to perform multiple sour ce cumulative impact assessments for that particular pollutant. Exceeding those SIL concentrations, however, triggers a NAAQS air dispersal analysis. WEPCO’s application shows SILs not excee ded for: 8-hour and 1-hour concentrations of CO; annual concentrations of NO

x ; and annual concentrations of SO 2 . Because their SILs were not exceeded, those pollutants and averaging intervals were not pursued by the compan y in the cumulative dispersion modeling an alysis. Those pollutants and averaging intervals where concentrations exceed ed the SILs were carried through the NAAQS analysis. 8

Table 4 summarizes the pollutant dispersion modeling results and how the resulting air concentrati ons approach the NAAQS, as pr ovided by WEPCO in its application materials. 9 TSP stands for total suspended particulates.

2 Ibid , p. 59, Table 2.18-6.

3 Ibid , p. 63, Table 2.18-9.

4 Lead is not a pollutant emitted in large amounts by power plant boiler systems burning coal, natural gas, or biomass.

5 Data from WEPCO application, p. 54, Table 2.18-1.

6 Information from WEPCO project application, Section 2.18, p. 54, Table 2.18-2.

7 Data from WEPCO project application, Section 2.18, p. 59, Tabl e 2.18-6. Includes CFB boiler and natural gas-fueled auxiliary package boiler plus diesel-powered feedwater pump, material handling systems, and cooling towers.

8 Annual concentrations of PM 10 appeared in the CA application and air permit application to exceed the SIL. Annual PM 10 is not included in the modeling because the state Natural Resources Board adopted the PM 2.5 NAAQS and repealed the annual PM 10 NAAQS in 2009.

9 Information provided by WEPCO in Technical Support Document, pages 62- 64, Table 2.18-10; and Prevention of Significant Deteri oration Air Pollution Control Construction Permit Application, pp. 51-54, Ta ble 7.3. “Cumulative impacts” include air concentrations r esulting from the proposed sources plus existing nearby sources as provided by DNR.- 32 - Table 4 WEPCO’s estimated expected cu mulative air concentrations and existing background concentrations of criteria pollutants compared with NAAQS, in micrograms per cubic meter (g/m 3 )

Pollutant Averaging

Interval Cumulative

Concentration Impact Background

Concentration Total

Concentration NAAQS Percentage of NAAQS

NO

x 1-hour 61 12 73 188 39%

SO 2 24-hour 249 11 260 365 71%

SO 2 3-hour 951 12 963 1300 74%

PM 10 24-hour 42 29 71 150 47%

PM 2.5 Annual 2 9 11 15 73%

PM 2.5 24-hour 9 26 35 35 99%

TSP 24-hour 104 40 143 150 96%

Lead 3-month 0.00066 0.01 0.01 0.15 7%

The NAAQS model factors in how the site layout and stack design maximize dispersion, using algorit hms developed by EPA. As a result, the modeled emissions summarized in Table 4 give a more accurate picture of the impacts of plant emissions on air quali ty than the

maximum allowable stack emission numbers shown in Tabl e 3. Also, the modeled air concentrations in g/m 3 are based on all the allowable emission rates in the area and the dispersion modeling algorithms, so there is no direct correlation between the allo wable emissions in tons per year, or expected emissions in tons per year, and the maximum predicted air concentrations in g/m 3 . As can be seen in Table 4, TSP and PM 2.5 would reach concentrations within 96 and 99 percen t of their NAAQS, respectiv ely. These expected

concentrations are close to viol ation of the NAAQS and might likely be the most logical pollutant situat ions to watch during pl ant operation.

One can see that the current ambient air modeling for this proposed project shows impacts similar to the current operations at Domtar while WEPCO’s projected estimated overall actual emissions are 30 percent less. According to DNR, there are several factors th at may influence this apparent discrepancy. 10 The modeling previously done fo r the current operations at Domtar have taken into account the existing layout of the facility, stack locations and parameters like height and exit velocity , allowable emission rates and ope rational factors like allowed hours of operation for the existing units, and the use of the then-approved air dispersion model software ISCST3. The modeling performed for the proposed WEPCO project would take into account the same factors but also utilize new, more rigor ous, modeling software (AERMOD). Th e differences in the facility layout, stack loca tions and parameters, a nd allowable emission rat es or operational factors for the proposed units would all play a role in how the impacts might change and whether they might increas e, decrease, or stay relatively the same. Therefore, it is not a one-to-one comparison based solely on emissions. Furthermore, t he WEPCO-projected 30 percent reducti on appears to be accounted on the actual emissions . “Actual” emission differs from the emiss ions utilized in an air dispersion model. The model utilizes “allowable” emission rates, which are normally much higher than expect ed or actual emissions. DNR staff point out that no direct comparison can be made between the projected 30 percent reduction in expe cted actual emissions and the projected allowable emissions because of the multiple factors utilized in an air dispersion analysis.

A county where monitoring data has resulted in a design value gr eater than the NAAQS is designated as a non-attainment county. Along with the obvious public health concern, being designated non-attain ment may have an adverse impa ct on economic development of a n area. Any major modification or major new emissions source would have to install the very best control equipment and find offs ets for new emissions. DNR has anecdotal evidence suggesting that i ndustrial sources looking to expand appear to avoid designated

non-attainment areas. 11

Regardless of whether the faci lity’s emissions meet the NAAQS, there is often a question of whether more sensitive individuals are adequately protected. In general, when air pollution levels in crease, sensitive individuals mi ght experience adverse respirato ry symptoms. The most vulnerable members of a population are generally the y oung, the elderly, and the infirm. Members of the public who a re most susceptible to environmental stress can often be found in hospitals, schools, daycare centers, and retirement homes. Two eleme ntary schools are located just over a half mile to the north and east of the project site. At least one, Rothschild Elementary Schoo l, has no central air conditioning system and must have the windows open during warm days.

It might also be noted that the American Lung Association presid ent wrote last year to U.S. Representatives Henry Waxman and Ed ward Markey, commenting on their legislative initiative for address global climate change and energy policy, and stated that,

10 Private communication with Jeffrey Johns on, DNR Air Bureau. August 10, 2010.

11 Public Service Commission/Department of Natural Resources joint Final Environmental Impact Statement for the WP&L 300 MW Power Plant, PSC docket 6680-CE-170, p. 153.- 33 - “The Lung Association urges that the legislation not promot e the combustion of biomass. Burning biomass could lead to significant increases in emissions of nitrogen oxides, par ticulate matter and sulfur dioxi de and have severe impacts on the health of children, older a dults, and people with lung diseases.” 12

Again, the NAAQS are based on EPA’s interpreta tions of scientific health impact resear ch related to those pollutants. Their pu rpose at EPA is to protect not only the general population but also suscep tible or more vulnerable populations, such as individuals with asthma, young children, and the elderly.

2.2.1.2 Hazardous air pollutants (HAP) including mercury

Hazardous air pollutants are a special classi fication of pollutants known also as toxi c air pollutants or air toxics under the Clean Air Act. The Clean Air Act requires EPA to reduce the routine daily emissi ons of air toxics first by a technology-based approach, and EP A has

created Maximum Achievable Contro l Technology (MACT) standards fo r each major type of facility within an industry group. The standards are based on emissions levels that are already being achieved by the better-controlled and lower-emitting sources in an industry (in this case, utility steam-electric generating units). The st andards are enforced under the Clean Air Act (and Wis. Admin. C ode ch. NR 445) as case-by-case MACT for projects that would reach threshold levels qualifying them as “major sources.” The emission of e ach HAP is being modeled by the DNR Air Bureau and adjusted to lim its that the DNR and EPA determine are appropriate. Permittable emission levels are expected to be low enough to protect human health according to the EPA.

A major source of HAPs under the federal Clean Air Act 13 is one that emits at least 10 tons per year of any individual HAP or more than 25 tons per year of the combined HAP emissions. Wis. Admin. Code ch. NR 445 lists and covers all federal HAPs plus several “state-only” HAPs that are not considered under the above threshol ds. WEPCO offers four categories of HAPs expected to be emit ted from the project: inorganic solid phase HAPs, inorganic acid-gas phase HAPs, organic HAPs, and mercury. While the natural gas -fired auxiliary boiler would emit a total of about one ton per year of all HAPs combined, the CFB would emit enough total HAPs per ye ar to qualify it as a major source of HAPs. WEPCO has applied case-by-ca se MACT in its air permit application materials. MACT would be applied to control emissions of all federal HAPs from the proposed project. The situation for ammonia, not a federal HAP, is d iscussed

below. The CFB would be classified as an industrial boiler because it would not com bust fossil fuels in gr eater than a thresho ld amount.

Inorganic solid phase HAPs, including heavy metals of concern, are listed in Table 5 and proposed in the company’s permit appli cation to be controlled with the fabric filter baghouse installed in front of the stack.

Table 5 Estimated potential emissions of inorganic, solid -phase HAPs predicted by WEPCO in tons per year

HAP Potential to Emit (tons per year) Antimony 0.028

Arsenic 0.077 Beryllium 0.004

Cadmium 0.014

Chromium 0.086

Cobalt 0.023

Lead 0.168 Manganese 5.606

Nickel 0.116 Phosphorus 0.095

Selenium 0.010

Inorganic acid gases are essentially hydrogen chloride (as HCl) a nd hydrogen fluoride (as HF) and are also to be controlled wit h the fabric filter baghouse. Both acids are corrosive. The project would be required to emit no more than about 14 tons per year of HCl g as and about 4 tons per year of HF gas. Recently-published EPA-propos ed industrial boiler MACT rules require the new MACT standard fo r HCl.

The organic HAPs that would be emitted by the CFB boiler are listed in Table 6. All qualifying HAPs are listed in this table b ecause they

were indicated to be emitted in absolute amounts even if thei r potential emissions round off to 0.0 tons per year to the neares t tenth of a ton. (Thus 0.0 tons per year can be translated as less than half a ton per year.) Organic HAPs of concern are more numerous t han the

12 Charles D. Connor, President and CEO, Amer ican Lung Association, letter to U.S. Repr esentatives Henry Waxman and Edward Markey

. June 24, 2009.

13 Section 112(b) of the Clean Air Act.- 34 - inorganic solid phase HAPs and include the individual HAPs that tr iggered the case-by-case MACT requirement (bolded in the tabl e). WEPCO’s application proposes “good combustion practices” as MACT for organic HAPs. Its proposed CO and VOC emission limits represent MACT limits. The total HAPs expe cted to be emitted by the next biggest source on the project, the natural gas-fired boiler, would total about one ton per year.

Table 6 Estimated potential emissions of organic HAPs for th e CFB boiler, in tons per year rounded to the nearest tenth

of a ton 14

HAP Potential to Emit (tons per year) HAP Potential to Emit (tons per year) Acetaldehyde 2.9 1,2-Dichloroethane (EDC) 0.1 Acetophenone 0.0 Dichloromethane 1.0 Acrolein 0.3 1,2-Dichloropropane 0.1 Benzene 2.6 2,4-Dinitrophenol 0.0 Benzo(a)anthracene 0.0 Ethyl benzene 0.1 Benzo(a)pyrene 0.0 Formaldehyde 2.2 Benzo(b)fluoranthene 0.0 Indeno(1,2,3,c,d)pyrene 0.0 Benzo(e)pyrene 0.0 2-Methylnaphthalene 0.0 Benzo(g,h,i)perylene 0.0 Naphthalene 0.3 Benzo(j,k)fluoranthene 0.0 4-Nitrophenol 0.0 Benzo(k)fluoranthene 0.0 Pentachlorophenol (PCP) 0.0 Bis(2-ethylhexyl)phthalate 0.0 Phenol 0.2 Bromomethane (methyl bromide) 0.1 Propanal (propionaldehyde) 0.0 2-Butanone (MEK) 0.0 Propionaldehyde 0.2 Carbon tetrachloride 0.2 Styrene 6.7

Chlorine 2.8 Tetrachloroethene (perchloroethylene) 0.1

Chlorobenzene 0.1 Toluene 3.2 Chloroform 0.1 1,1,1-Trichloroethane 0.1 Chloromethane (methyl chloride) 0.1 Trichloroethene 0.1 Dibenzo(a,h)anthracene 0.0 Trichl orofluoromethane (CFC-11) 0.1 1,2-Dibromoethene 0.2 2,4,6-Trichlorophenol 0.0 Polychlorinated biphenyls (PCBs) 0.0 Vinyl chloride 0.1 2,3,7,8 TCDD equivalents (dioxins and furans) 0.0 o-Xylene 0.1

Benzene and formaldehyde both would be emitted in amounts over 10 tons per year in WEPCO’s original air pollution control permi t and so would trigger the need for WEPCO to do a case-by-case MACT on HAPs. However, the emission factors for benzene and formaldehyde have been updated by EPA for industrial boiler MACT standards, and WEPCO’s new es timates based on the new MACT

standards would each be less than 10 tons per year. 15 Based on these updates and others, WEPCO’s states that its total summed potential HAP emissions would be reduced from 122.2 tons per year in its orig inal air permit application to 52.7 tons per year. This tot al would still trigger the need for case-by-case MACT, so WEPCO has applied MACT in its application. MACT analyses are being performed by the DNR Air Management Bureau as part of the air permit review at the DNR.

Mercury is an air toxin of great concern and is regulated partic ularly under Wis. Admin. Code ch. NR 446 but also subject to ca se-by-case MACT. Mercury may be an issue with tree ba rk because trees have taken it into thei r systems. Currently, over 300 Wisconsin la kes and river stretches carry fish consumption adviso ries for mercury. Mercury accumulation in fish-consuming wildlife can lead to rep roductive problems. Human consumption of fish that contain mercury can da mage the nervous system, especia lly in children and fetuses. M ercury emissions may not exceed 2.9 pounds per trillion Btu from the boiler. CFB emissions of mercury would be controlled with the fa bric filter baghouse according to the WEPCO air pe rmit application. EPA recently proposed na tional emission standards for control o f

14 The emissions estimates in Table 6 are from WEPCO response to Commission staff data request 3.08. The applicant has estimated HAP emissions from the facility by applying the limits in the June 4, 2010 proposed industrial boiler MACT. On August 18, the Gove rnor and DNR Secretary submitted comments to the EPA on its proposed indus trial boiler MACT rule, requesting revisions to the EPA’s appr oach to MACT for biomass boilers. It is possible that the final industr ial boiler MACT rule will include different standards for bioma ss-fired plants than those included in the proposed MACT standard. Estimated le vels for organic HAPs with currently proposed MACT standards th at would result in less than 0.5 tons per year appear as 0.0 in Table 6.

15 Table 6.2 of WEPCO’s Air Pollution Control Construc tion Permit, on HAPs, was revised 7/9/2010. PSC REF #134769.- 35 - mercury emissions from biomass-fired area source boilers and for other hazardous air pol lutants based on EPA’s proposed determi nation about what constitutes the generally availa ble control technology or management practices. DNR is planning to use the EPA-prop osed biomass MACT as MACT for the proposed boiler, unless WEPCO s hows how it does not represent new source MACT for the project. 16
The recently-published EPA-proposed industria l boiler MACT rules include an updated MACT standard for mercury. With that updat e, the precise estimate of mercury emissions in WEPCO’s air permit application has been updated from 0.010 tons per year to 0.0007 tons

per year.

Local citizens have expressed concerns about dioxins and furans being produced as organic HAPs byproducts of the biomass combus tion. According to WEPCO’s air pollution permit application, and as seen in Table 6, di oxins and furans would be produced. Trace am ounts of dioxins and furans are emitted from any combustion process, including biomass combustion. They are already produced by the existing Domtar mill at the level of nanograms per kilogram of mill sludge as well. These products are distributed mainly thro ugh the air, enter our system when we eat contaminated food, and typically stay and build up in the fatty tissues of animals. 17 Potential effects of

dioxins and furans in humans include cancer and changes in hormone levels. The recen tly-published EPA-proposed industrial boil er MACT rules include updated HAP limits for some MACT standards, including that for dioxin/furan emissions. The dioxin/furan MAC T standard will likely be 1.5 x 10-10, or 0.00000000015 tons per year . To the nearest tenth of a ton per year, this level appear s as zero in Table 4. It is less than one percent of one pound. According to WEPCO’s air permit application, dioxin and furan emissions fr om the CFB boiler would be minimized by good boiler design and good combusti on control, which minimizes precursor formation. This con trol

method also minimizes emissions of other organic hazar dous air pollutants such as formaldehyde.

Applying the emission limits from the EPA’s proposed industrial boiler MACT standards, potential dioxin/furan emissions from th e CFB boiler would be 0.00000031 pounds per year (or 310 billionths of a pound). WEPCO must compare this emission rate to the most t oxic members of the category: 2,3,7,8-tetrachlorodibenzo-p-dioxin a nd 1,2,3,7,8-pentachlorodibenzo-p-dioxin. The comparison is sta ted as Toxic Equivalency (TEQ). DNR’s threshold em ission rate for dioxins and furans under Wi s. Admin. Code § NR 445.07, Table A, is 0. 0001 pounds per year TEQ. The above potential dioxin/furan emissions from the CFB boiler would be less than 1/300th of the thr eshold amount for DNR regulation under Wis. Admin. Code ch. NR 445. So , expected potential dioxin and furan emissions would be far be low the threshold level that would require regul ation under the health-based air toxics rules in NR 445. The estimated levels may change as the DNR processes WEPCO’s permit application.

Ammonia, which is not a federal HAP, would be emitted by the project as a result of “ammonia slip” from the SNCR NO

x control system. In its air permit application, WEPCO estimates ammoni a emissions from the stack to be about 122,303 pounds per year (a bout 61 tons per year). This level is lower than the threshold for state action in Wis. Admin. Code § NR 445.07.

2.2.1.3 Dust and particulate matter

According to the CA application, the plant’s fuel conveyor an d processing systems would have dust collection systems installed at transfer and processing points as WEPCO’s proposed BACT. Air collected at these points would run through a fabric filter bagho use to remove particulates before bei ng exhausted to the atmosphere. According to A ppendix C of the air pollution control constructio n permit application, 18 emissions of PM and PM 10 are estimated to be controlled to about 16 tons per year each and emissions of PM 2.5 would total about 8.2 tons per year. These levels might be lower after the company and DNR refine the expected emissions while DNR process es the permit application.

WEPCO’s air permit application describes its proposed BACT for the biomass truck unloading as a self-unloading truck system in combination with a wet dust suppression system. The wet dust suppression system does not induce an air flow out of the unloadi ng enclosure and so reduces the amount of PM emitted. The combined use of the enclosure and the wet dust collection system would keep total PM emitted at about 538 pounds per year.

Conducting biomass storage and reclaim inside a building, which WEPCO is proposing as BACT, would reduce PM emissions by over 90 percent from what they would be outside. The storage silos w ould have vent filters, as would the ash handling and storage s ilo system.

WEPCO also proposes to pave all roadways and use dust suppression on roads when necessary as BACT to control fugitive dust. Th e company expects that this would reduce dust by about 85 per cent over doing nothing. The company estimates emissions of PM 2.5 to be about 0.41 tons per year on biomass fuel delivery roads and about 0.0015 tons per year on ash truck roads. Emissions of PM 10 would be about 0.276 tons per year on biomass delivery roads and about 0.0104 tons per year on ash truck roads. Emissions of PM otherwi se

16 Letter from Steven Dunn, DNR Air Bureau, to Terry Coughlin, WEPCO. June 30, 2010.

17 EPA Dioxins and Furans Fact Sheet. www.epa.gov/osw/hazard/wastemin/minimize/factshts/dioxfura.pdf

. 18 PSC REF #132222. A copy of the permit application and permit-re lated correspondence to date has been filed as a supplement to Technical Support Document Appendix G, State Permits, Notices and Approvals (PSC REF #132184).- 36 - would be about 1.417 tons per year on biomass delivery truc k roads and about 0.0533 tons per year on ash truck roads.

A small amount of particulate matter would also be emitted from the cooling towers as droplets that drift through the system ev aporate. The company indicates that PM emissions would be at about 0.386 tons per year, PM 10 emissions would be at about 0.317 tons per year,

and PM 2.5 emissions would be at about 0.00087 tons per year. WEPCO’s plan is to use high efficiency droplet drift eliminators to control

PM to these levels.

2.2.1.4 Greenhouse gases

GHGs would be emitted by the project duri ng operation. Potential impacts of GHG emis sions on global climate change and its pot ential effects are described in the reports of the Intergovernmental Panel on Climate Change, the scientific body set up by the World Meteorological Organization and the United Nations Environment Pr ogramme to provide an objective source of information about gl obal climate change. 19 Potential impacts worldwide and in Wisconsin, including costs of mitigation, are summarized in the environmental impact statement issued in 2008 that discusses Wisconsin Power and Light Company’s (WP&L) proposed Nelson E. Dewey Generating

Station Unit 3. 20

Carbon dioxide (CO 2 ) and nitrous oxide (N 2 O), which would comprise most of the GHG em itted from the CFB boiler, are discussed in

this subsection. 21 Other GHGs include methane (CH 4 ) and fluorocarbons. In response to staff data requests, WEPCO provided

information about GHG emissions with the ca veat that its understanding is that the CFB boiler burning biomass would be “carbon neutral.” As shown in Table 7 below, the CFB would emit 590,000 tons of CO 2 per year. This emission rate for the plant’s proposed energy output would be equivalent to 1,815 pounds per MWh. That rate could compare with 1,853 pounds per MWh for the relativel y new Weston Unit 4 supercritical pulverized co al-fired boiler. WEPCO points out that the commonly recognized difference between a biomass and coal plant is that carbon released from combustion of bi omass is presumed to be absorbed or “resequestered” by othe r biomass as it grows, making the biomass plant “carbon neutral.” A discussion of the carbon neutral argument is below. In Tabl e 7, the emission levels are shown in tons per year and CO 2 equivalents (CO 2e ). The global warming potential of N 2 O emissions is 310 times that

of CO 2 , so N 2 O emissions are also given as CO 2e

.

Table 7 WEPCO estimates of CO 2 and N 2 O emissions in tons per year from the proposed project, including N 2 O as CO 2 equivalents

CFB Boiler Emission Natural Gas Auxiliary Boiler

Emission Greenhouse

Gas Tons/yr emitted Tons/yr CO 2e Tons/yr emitted Tons/yr CO 2e Diesel Feedwater Pump Emission

CO 2 590,000 590,000 13,000 13,000 17

N 2 O 39 12,090 0.2 62 -

Total CO 2e 602,090 13,062 17

Adding up total tons per year in CO 2e from the plant results in a total of 615,169 tons of CO 2e

.

Commission engineering staff has performed modeling analyses on se veral generation alternatives to this plant using the followi ng assumptions:

 the CO 2 emissions would be five percent greater than WEPCO’s esti mate to account for the presence of running diesel trucks on the plant site

 the N 2 O emissions would be twice the amount estimated by WEPCO because of uncerta inties related to the choice of a CFB

boiler

The intervener SOAR has suggested that the additional impact of N 2 O emissions on the total CO 2e should be notably greater, but WEPCO’s information and Commission engineering staff adjustments both seem to result in N 2 O emissions being a small percentage of

the total CFB boiler emissions. If WEPCO’s estimated N 2 O emissions from the CFB boiler are included in CO 2e , the amount of CO 2e from the CFB boiler increases by approximately two percent. If th ey are doubled, as in the engineering staff modeling, the amo unt

19 For example, Climate Change 2007: Synthesis Report. Contribution of Work ing Groups I, II and III to the Fourth Assessment Report of the Intergovernmental panel on Climate Change

. 20 Public Service Commission of Wisconsin and Wisconsin Department of Natural Resources. WP&L 300 MW Power Plant Final Environmental Impact Statement. PSC docket 6680-CE-170. July 2008, pp. 135-152.

21 Although N 2 O is an oxide of nitrogen, it is not a criteria pollu tant. Wis. Admin. Code § NR 400.02(107) defines NO

x as “all oxides of nitrogen except nitrous oxide.”- 37 - increases by approximately four percent. If the CO 2 emissions are increased by five percent to account for trucks as part of the CFB emissions, the total CO 2e emitted increases to 619,500 tons but the doubled emission estimate of N 2 O would still be approximately four percent of the CFB CO 2 output.

The final determination of N 2 O and CO 2e emission limits will, as discussed below, be part of the DNR air pollution control permit.

The following discussion is primarily based on CO 2 or its surrogate term, “carbon.”

GHGs, including CO 2 , are now considered by the EPA to be pollutants covered under the Prevention of Significant Deterioration (PSD) and Title V programs of the Clean Air Act (CAA). Under the recently issued EPA Greenhouse Gas Tailoring Rule , a project emitting over 75,000 to ns of GHGs per year in CO 2e would be required to obtain a permit with BACT and comply with existing PSD regulations for CO 2e under the Clean Air Act as of January 2, 2011 if the project was also significantly increasing emissions of at least one non-GHG pollutant. To obtain the pe rmit, the facility would have to demonstrate that it was using the best practices and technologies available to minimize GHG emissions. The permit would be part of the state’s air pollution control perm itting. The Tailoring Rule set the threshold for GHG emissions a s a criteria pollutant at a level high enough to be seen as a feasible level for enforcement.

At this time, the Tailoring Rule provides little distinction between biomass-fired power plants and coal-fired power plants, bu t the biomass industry is striving to effect rule changes that would avoid disincentivizing biomass power. 22 The EPA has issued a Call for

Information 23 that serves as a first step in considering sepa rate options for addressing emissions of biogenic CO 2 under the PSD and Title V programs. The Call’s purpose is to request comments on how a di fferent approach for biomass pl ant emissions might be develop ed for the PSD and Title V Programs, and to solicit information about biomass-fired sources and their emissions, technical methods of accounting for these emissions, and the underlying science that might help de velop possible accoun ting approaches.

In Wisconsin, the regulation of GHG emissions by the EPA will be done through the state DNR air pollution control permitting pr ocess. It is expected that GHG will be addressed in the DNR air pollution control permit for this project. At this time, the proposed project

emissions would exceed the criteria thres hold under the pending federal la w and require the company’s air permit to apply BACT as of January 2011.

At the time of preparation of this EA neither CO 2 nor N 2 O are regulated under the Clean Air Act or Wisconsin Administrative Code. There are no specific control requirements for the proposed CFB boi ler and no other similar facility available for comparison t hat has GHG controls classified as BACT. However, the Wisconsin DNR is intending to apply BACT for GHGs in the air pollution control permit for the Rothschild biomass facility. The draft air permit is expected to be completed in mid-November, 2010. 24 (The draft EA by DNR staff is expected to be issued about the same time. 25 )

As stated above, WEPCO has maintained that biomass energy is considered carbon neutral in Wisconsin, meaning that carbon releas ed from combustion of biomass is presumed to be absorbed or captured by other biomass as it grows. No clear declaration of Wiscon sin state government policy on biomass energy could be found, but WEPCO points out that the Governor’s Task Force on Global Warming (GWTF) and proposed federal legislation treat biomass as carbon neutral. However, EPA intends to regulate GHG emissions from biomass-fired power plants starting in January 2011, and thus doe s not appear to consider biomass combustion to be carbon-neutr al at this

time.

The concept of “carbon neutral” in this context may be more comp licated than recognized at first glance. The GWTF’s Biomass an d

Biofuel Recommendation includes this caveat :

“Some bioenergy feedstocks, conversion technologies, and end uses have lower life-cycle carbon emissions than others. It is therefore the intent of this policy proposal to promote those bioenergy sources with the most favorable life-cycle carbon emissions. In crafting specific policies, the relative efficiency and carbon emission impact of biomass

must be evaluated.” 26

22 Dixon, Darius. “Industry claims emissions rule could devastate fu ture of biomass.” Greenwire. June 9, 2010. Bravender, Robi n. “Biomass industry sees ‘chilling message’ in EPA emissions rule.” Greenwire. May 14, 2010.

23 U.S. Environmental Protection Agency. Call for Information: Information on Greenhouse Gas Emissions Associated with Bioenergy and Other Biogenic Sources. Docket ID No.EPA-HQ-OAR-2010-0560.

24 Steven Dunn, DNR Air Management Program, personal communication, October 6, 2010.

25 Thomas Lovejoy. DNR Environmental Analysis and Revi ew Supervisor, personal communication, October 6, 2010.

26 Final Report of the Governor’s Task Force on Global Warming: Wisconsin’s Strategy for Reducing Global Warming . July 2008. ( http://dnr.wi.gov/environmentprotect/gtfgw/documents/Final_Report.pdf ) Appendix E: Task Force Recommended Policies. Biomass and- 38 - The recent report by the Manomet Center for Conservation Sciences, co mmissioned by the state of Massachusetts, cites the 2009 s tatus report of the International Energy Agency (IEA) as the state-of-the-art thinking on the impacts of forest biomass combustion on GHGs. 27
The IEA points out that the amount of GHG emission reduction from bi omass harvest and use options is “complicated by the fact t hat the performance of the different options is site-specific and is determ ined by many parameters.” The more critical parameters that affect

relative GHG emissions reduction from forest biomass include:

 The productivity and regenerative ability of the biomass harvest site and the efficiency with which the harvested material woul d be used;

 The fossil fuel system that would be replaced;

 The amount of the carbon storage in a site’s soils a nd vegetation that would have to be resequestered;

 The timescale being considered for sequestration.

According to WEPCO, CO 2 emission levels related to the combustion of biomass are expected to drop from current levels at the Domtar mill to a net level of zero with the coge neration plant because the fuel would cha nge from natural gas and other fuels to woody materials that can be regenerated. WEPCO points to the Technical Advisory Committee of the GWTF, which determined that CO 2 emissions from a biomass plant should be considered to be a net leve l of zero for purposes of modeling GHG reduction policies. 28 The company indicates that forest regeneration in the biomass source areas, or somewhere, should eventually sequester the same amount of CO 2 emitted by the proposed project. If compared to the timescale required for sequestering the amount of CO 2 that would be released during the combustion of coal or natural gas, this process represents a conceptual “closed loop” life- cycle for the pollutant.

The amount of CO 2 sequestered by the regenerating forest or new plantations would depend on the health of the source forest or plantation areas and the effort made to ensure that the amount sequestered would be equivalent in carbon content to the amount consumed at the plant. When a tree’s carbon (or the carbon from a portion of a tree) is released into the atmosphere in a single pulse through combustion, it contributes to atmospheric GHG concentrations (and global climate change potential) much more rapidly than woodl and timber rotting slowly over decades.

Several factors could affect the relative levels of CO 2 added to the atmosphere, including the carbon content of the tree material being consumed in contrast to the carbon content of the trees grown for regeneration. If more whole trees were chipped for combustio n, for example, the regenerating forest would need to grow to the matu rity level of those harvested whole trees in order for the syste m to approach a carbon neutral state. If the biomass burned at the Do mtar cogeneration plant were en tirely harvest residues, the re generating forest could sequester that much carbon in less time than it would take to grow the whole tree. Regeneration of the woodlands harvested as whole trees for other industries, like wood products or paper-making industries, would represent a different CO 2 sequestration life cycle. 29

When the entire carbon cycle is examined, additional CO 2 emissions during harvest, transport, and handling are considered. There also

would be some CO 2 production from machinery operation related to the boiler and fu el handling. Research identified so far indicates that precise estimates of CO 2 emission can be made but the accuracy of estimates suffers from the uncertainties related to the type and care of the different pieces of equipment used, th e types of landscapes harvested, and the distance from each biomass source to the pow er plant.

The CO 2 emissions related to hauling the biomass to the plant can be es timated. The U.S. Department of Energy’s Energy Information

Administration estimate of CO 2 emitted from burning one gallon of diesel fuel is 22.384 pounds per gallon. WEPCO states that there would be 18,000 trucks per year delivering biomass fuel to the south entrance. 30 This would equate to 36,000 trips per year from the wood source to the plant and back to the wood source. Elsewhere in its ap plication, WEPCO says that there would be an addition al 75 trucks per day that would be primarily biomass fuel delivery , equating to about 19,500 round trips or 39,000 one-way trips per year. Using the 75 trucks-per-day estimate, the CO 2 emissions from trucks delivering biomass to the plant from 75 miles away would be about 6,552 tons of CO 2 per year if those 75 trucks per day delivered fuel on wee kdays all year getting about five miles to the gallon and

Biofuel, p. 155.

27 IEA Bioenergy. 2009. Bioenergy – a Sustainable and Reliable Energy Source . Energy Research Centre of the Netherlands, E4Tech, Chalmers University of Technology, and the Copernicus Institute of the University of Utrecht. In. Manomet Center for Conservat ion Sciences. June, 2010. Biomass Sustainability and Carbon Policy Study. Prepared for the Commonwealth of Massachusetts. Report NCI-2010-03, pp. 11-12.

28 WEPCO CA application, Technical Support Document, Section 2.18.3, p. 65.

29 Testimony by Commission staff witness Dennis Koepke discusses this point briefly in rebuttal testimony for the Northern States Power-Wisconsin Bay Front Boiler 5 project (PSC docket 4220-CE -169) and cites the report by the Winrock Foundation for the GWTF that

showed that sustainable timber harvest could be net carbon neutral. PSC REF #119012.

30 Table 2.37-1, p. 81, Technical Support Document, CA application.- 39 - releasing 22.384 pounds of CO 2 per gallon of fuel burned. This figure, 6,552 tons of CO 2 from fuel hauling, is quite small (just over 1.0 percent) compared to the annual CO 2e emissions from the CFB. (See Table 5.)

Domtar has indicated that fuel could come from as far away as 100 miles from Rothschild, but is more likely to come from within 75 miles. (See Attachment 6.) 31 If that distance is at the upper economic hauling lim it range for biomass fuel (a worst-case scenario), and because more fuel would likely be harvested and delivered from le ss than that distance, an aver age hauling distance could be ab out 37.5 miles. Using the 75 trucks-per-day estimate for tr ips and the fuel consumption values above, the CO 2 emissions from trucks delivering biomass to the plant from 37.5 miles away would be about 3,276 tons of CO 2 per year. This figure is only about 0.5 percent of the

amount of CO 2e emissions that would be released from the CFB boiler.

An estimate of CO 2 emitted during harvesting and chipping at the logging site is mo re difficult to obtain at this point, but it could be in the same range of emission levels. Thus, it appears that while the CO 2 emissions associated with harv esting, hauling, and conveying the biomass to the boiler on the plant site are part of the carbon lif e cycle emissions of biomass, these values are quite small (l ess than 3.0 percent) in comparison to the amount of CO 2 emitted during the combustion process. These CO 2 contributions potentially could be less if a portion of the truck fuel used was biodiesel rather than regular diesel fuel.

Burning the biomass in the CFB boiler would create ash as well. WEPCO estimate s 1,000 truckloads of ash from the CFB each year

.

Burning diesel fuel to haul the ash is a necessary activity re lated to the biomass carbon cycle. If the ash is land spread, it would probably be hauled up to about 40 miles away, to Marathon or one of the surrounding counties. If spreading is not an option, WEPCO inte nds to truck it to either Pleasant Prairie in Kenosha County or the El m Road Generating Station south of Milwaukee, approximately 200 miles away. At 1,000 truck loads per year, or 2,000 one-way trips out and back, land spreading the ash would lead to about 179 tons of CO 2 emitted by ash trucks per year if it is spread locally in Ma rathon County or nearby. If all the ash was trucked to Pleasant Pr airie or Elm Road, about 895 tons of CO 2 would be emitted annually. This figure is about 0.1 percent of the CO 2e expected to be emitted from the CFB boiler, a relatively small contribution.

The residue from logging that would not be harvested for the c ogeneration plant would degrade over time as it decayed on the fo rest floor, releasing CO 2 , and methane, another GHG gradually without the relative bursts of CO 2 emissions from combustion in the boiler.

2.2.1.5 Truck emissions

CO 2 emitted from trucks hauling biomass is discussed in the previous section. However, diesel exhaust includes much more than GHG s.

People living in the project area have expressed concern about ai r pollutant emissions from trucks at the plant site and along Business USH 51 (Grand Avenue). Truck traffic coming through the south mill entrance would be closest to the neighboring residences immediately south of the mill property and across the street from the entrance. Truck traffic through the north entrance would be closer to other residences and Rothschild Elementary School, where concern has also been expressed about air quality. According to WEPCO , the number of trucks coming through the south entrance per day over a 12-hour period, five days per week, year-round would increase from approximately 35 to 110. Truck traffic through the north entran ce would decrease and consequently, so would truck emissions. In the Rothschild area overall, biomass fuel delivery, ash hauling, a nd delivery of power plant chemicals would contribute to increase s in diesel air emissions on the plant site and on Business USH 51 north to the STH 29 interchange and south to the I-39 interchange, a dis tance of about 1.8 miles. (Potential truck traffic im pacts are described further in Section 2.2.4.)

Diesel exhaust is composed of two phases, gas or particle. The gas phase is compos ed of several urban hazardous air pollutants , such as acetaldehyde, acrolein, benzene, 1,3-butadiene, formaldehyde, a nd polycyclic aromatic hydrocarbons. The particle phase also ha s many different types of particles, varying in co mposition but mostly classified by size. The sizes of diesel particulates of greates t health concern, according to EPA, are fine and ultra-fine particles. 32 The fine and ultra-fine particles might be composed of elemental carbon with adsorbed compounds such as organic compounds, sulfate, nitrate, metals, and other trace elements. There is limited eviden ce indicating that inhalation of diesel exhaust causes acute and chr onic health effects. Acute ef fects could include irritation t o the eyes, nose, throat, and lungs, some neurologi cal effects such as lightheade dness, and a cough or nausea or exacerbation of asthma. Diesel particulate is classified by EPA as a suspected human carcinogen. One coul d assume that cancer is a non-threshold process where even a ver y small amount of carcinogen has some level of risk associated with it. Human epidemiological studies have shown an association betwee n diesel exhaust exposure and increased lung cancer rates in occupational settings.

It is not clear how close and how chronic the exposure must be in an occupational setting, but it is likely that the nearby res idents and

31 This attachment is adapted from “Map 2,” a staff-produced att achment to the Commission’s original public notification letter.

32 “Diesel Particulate Matter.” EPA. Air Toxics in New England. http://www.epa.gov/region1/eco/airtox/diesel.html

.- 40 - students in Rothschild would not be in an occupational se tting relative to the trucks at issue in this case.

WEPCO has provided estimates of the increase in truck tailpipe emissions and resuspended road dust using models provided by DNR and

EPA. 33 These do not include GHG emissions. Ultra-low-sulfur diesel fuels to be used by the trucks would make levels of SO 2 emissions from truck traffic negligible. On the project site, trucks woul d use the southern entrance to the Domtar property off Business USH 51 and follow the path shown in Attachment 2 to and from the biomass fuel unloading station. This is a distance of about 0.57 miles. There would be very little idling because the trucks are expected to be dispatched so there would be very little waiting. 34 However, if trucks did need to wait for some reason, it would decrease diesel combustion emissions if their engines were turned off. WEPCO’s truck em ission estimates for the plant site are given in Table 8, based on the pr ojected increase of 75 trucks per day. These emissions would be in addition to the existing mill truck emissions and the expected emissions from the cogeneration plant facilities themselves.

Table 8 WEPCO’s estimated biomass deli very truck emissions on the cogenera tion plant site in tons per year

Pollutant Annual Emission Rate Increase (tons per year)

NO

x 0.21

VOCs 0.006

CO 0.04

PM 2.5 0.30

It is probable that more than one truck would be at the weigh s cales or dumpers at a time so that some trucks would be waiting and idling instead of moving along the 0.57 miles of roadway. According to EPA, about one gallon of diesel is burned per hour during idli ng. 35
While the emissions resulting from following the path from the entrance to the unloading area maybe be relatively low, it may s till be appropriate to limit the amount of truck engine idling at the Roth schild plant as deliveries wait to be unloaded. This could b e done by having a truck idle no longer than a certain number of minutes befo re the engine must be turned off. Or, it could be done by l imiting the numbers of trucks, through scheduling and dispatching, that coul d be on the property waiting to unload. EPA indicates that, to minimize risk, it would be helpful if the trucks we re required to avoid unnecessary idling by tu rning off the engine when the truck is n ot in motion. Operators could also be encouraged or required by the company to keep their vehicles in proper condition. And, there are pollu tion

control devices that could be retrofit in to the muffler areas of diesel engines. 36

WEPCO states that trucks would be shut down when they are bei ng unloaded. Trucks waiting to unl oad would queue in the road bet ween the weigh scales and the truck dumpers, immediately south of the boiler building. Empty trucks waiting to weigh out (if there was a wait) would be idling in the same area going in the opposite direction. One could also assume that full trucks waiting to be weighed would idle, while queued before the weigh-in scale, sout h of the truck dumpers and north of the biomass storage building. WEPCO states tha t it is likely that the trucks would idle while they wait to be weighe d and unloaded, but also that waiting could be minimized by havin g a plant dispatcher schedule the truck arrivals and entry to the plant. Dispatched entry would reduce and limit the amount of time for trucks to wait and idle. Weighing and unloading locations are illustrated in Attachment 2.

The DNR air pollution control permit that applies to stationary sources like the proposed boiler does not apply to mobile sourc es like delivery trucks. Emissions from truck traffic are included in th e air permit modeling only as part of the background concentra tions. 37 It is not likely that projected truck traffic woul d be included because it would not be me asurable until the project was approved and operating. However, it appears that cumulative increase in PM 2.5 emissions related to the projected amount of truck emissions would be a relatively small when compared to the projected amount of PM 2.5 emissions from the proposed CFB boiler. Using values supplied by WEPCO in its application or the data request responses, the estimate of 0.30 tons per year of PM 2.5 emissions from the additional biomass delivery trucks on the power plant site (See Table 8) would be about 1.5 percent of the amount of total PM emissions expected from the proposed CFB boiler and about 0.32 percent of the estimated maximum allowable emissions of PM 2.5 for the entire proposed project with BACT (See Table 3). Between its stationary and mobile source programs, DNR ’s Air Management staff is not considering those increases lar ge enough to cause the proposed project to exceed NAAQS.

Considering mobile sources, EPA has a “hot spot” analysis mode l for looking at high-truck-traffic projects. The traffic thresh old for needing such an analysis for air pollution impacts is relatively high. The analysis is used mainly for new truck terminals, fr eeways, and

33 WEPCO response to PSC Data Request 01.70. PSC REF #132730.

34 Personal communication with Dave Derment, WEPCO. October 5, 2010.

35 http://www.epa.gov/region1/eco/diesel/pdfs/Diesel_truck_bus_CT.pdf

. 36 Roundy’s Supermarkets, Inc. has retrofit some of its tr uck fleet in this way. (“A Retrofit for Roundy’s” In Diesel Progress , October 2005, pp. 50-51.)

37 Personal communication with Steven Dunn, DNR Bureau of Air Management. October 6, 2010.- 41 - arterials in nonattainment areas. DNR staff indicates that the Rothschild plant would not likely meet the threshold for such a n analysis. 38
An example situation that would be covered by this federal law 39 would be a project on a new highway or expressway that serves a significant volume of diesel truck traffic, such as a facility with greater than 125,000 annual average daily traffic (AADT) wh ere eight percent or more of the AADT (at least 10,000 vehicles) is diesel trucks. An example of a recent analysis for an indirect sourc e air permit was done for a Roundy’s Supermarkets, Inc. (Roundy’s) proposal to build a large distribution center in Waukesha County. The ce nter would have over 200 trucks arriving and leaving the site each day, some remaining on the site for more than an hour, with 40 to 90 trucks idling or running on site in any hour. Rules were established at the facility to limit idling time and to schedule truck arriv als so that no trucks entered the facility more than four hours pr ior to or one hour after an arranged appointment time.

Because the major increase in truck traffic at the south entrance would be for biomas s deliveries, WEPCO provided estimates for biomass truck delivery emissions on Business USH 51 between STH 29 and I-39. The estimates are shown in Table 9.

Table 9 WEPCO’s estimated biomass deli very truck emissions on Business USH 51 between STH 29 and I-39 in tons per

year

Pollutant Annual Emission Rate (tons per year)

NO

x 0.96

VOCs 0.03

CO 0.18

PM 2.5 0.21

Some comparison between the estimated pollutant amounts on Business USH 51 and the existing air pollution situation on that str etch of highway would be useful. Because the triangle of roads formed by I-39, STH 29, and Business USH 51 would likely be the local r oads used in biomass delivery, WEPCO used the DNR model and EPA emi ssion factors to estimate current emissions from all traffic on t his triangle for comparison. Its summary, showing emissions in pounds per day, is shown in Table 10. Again, GHGs and SO 2 were not
included.

Table 10 WEPCO’s estimated current vehicle emissions and futu re biomass fuel delivery truck emissions in pounds per day for the I-39/STH 29/Business USH 51 road triangle

Pollutant Future biomass fuel delivery truck emissions (lb/day) Current vehicle traffic emissions (lb/day) Future fuel delivery emissions as a percent of current traffic emissions

NO

x 19 792 2.4%

VOCs 1 295 0.3%

CO 4 3497 0.1%

PM 2.5 4 142 2.8%

This information indicates that none of these pollutants, includ ing volatile organics and fine particulates, would increase bey ond 3.0 percent over current pollution levels as a result of the increased number of biomass fuel delivery trucks.

38 Personal communication with Michael Friedlander, DNR Bureau of Air Management. June 29, 2010.

39 CFR § 93.123(b)(1)(i) and (ii).- 42 - Attachment C

DNR Draft Air Permit

DNR completed their draft permit on DATE. A copy of DNR’s draft permit is available on the DNR’s Air Program website using the following link and instructions: Website link: http://dnr.wi.gov/cias/am/am external/AM_PermitTr ackingSearch.aspx.

Instructions:

1. In the ‘FID’ box, enter “737227040” (no quotes), and click on the ‘Search’ button near the bottom right.

2. A record will appear under the search area. Click in the checkbox under the ‘Sel.’ fiel d. [note: the screen will then refresh, please be patient as this may take up to a few minutes.]

3. In the next screen, scroll down to the ‘Permits and Permit Applications’ section, and click on the ‘Select’ link next to permit number 10-SDD-058. This will populate the ‘Permit Document s’ section immediately below the ‘Permits and Permit Applications’ section.

4. In the ‘Permit Documents’ section, click on the ‘Download’ link next to document ‘FILE NAME’, to download a copy of the draft permit.

5. Other permit documents can be downloaded the same way, incl uding the Preliminary Determination and the air dispersion Modeling Analysis report.