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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 Facility at Domtar Paper Mill, Rothschild

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

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

Title of Proposed Amendment: Amendment to Wisconsin Public Service Commission (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 Department 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 original assessment and the reasons for the change. 

WEPCO is proposing to construct, install and place in operation equipment that will combust biomass to provide 50 megawatts (MW) 

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 storage 

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 WEPCO biomass boiler would replace four existing 

Domtar boilers. Existing Domtar industrial water supply and wastewater systems would be adequate for use in the new biomass 

energy facility. Minor changes for biomass fuel handling/storage and access gate/roadways would be made at the existing mill site. 

The project requires a PSC Certificate of Authority (CA), for which PSC is first required to prepare an environmental assessment to 

identify and consider potential project environmental impacts prior to a CA decision. PSC completed their EA on October 22, 2010. A 
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copy of PSC’s EA is available on the PSC’s Electronic 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/apps35/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” and 

“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 these 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 alternative 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 prepare 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 decided 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 approach 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 described 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 issues/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 warranted 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 independent 

analysis, using USEPA-approved modeling technology, to make its own conclusions whether the project will comply with air quality 

standards. DNR will add enforceable equipment or operational controls to ensure emission standards are met. 

The DNR uses dispersion modeling to evaluate the ambient air impact of air pollution sources. The following is a brief description of 

how that process works. A model is a mathematical simulation, designed to predict what can or will happen in real-world scenarios. 

Atmospheric dispersion modeling is useful in predicting the impact a particular facility will have with respect to a given pollutant. The 

major benefit of dispersion modeling is that it is an inexpensive 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) standards, both federal and state. Dispersion modeling incorporates information 

about a facility, such as source/stack parameters, facility layout information, and 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 result of (besides other factors) inversions. The pollutant 

concentration at the point of highest impact is added to a previously 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 result of that independent analysis, including the air dispersion 

modeling analysis. 

The second subject addressed in this EA amendment is in response to public interest and comments this project has generated. Since 

WEPCO’s air permit application was first submitted to DNR in March, 2010 we received a steady stream of emails, letters and calls 

from concerned citizens about potential project impacts. Most contacts came from sources concerned about or opposed to the project, 

the majority from a citizens group called Saving Our Air Resource (SOAR). Prevailing points were that the project air emissions
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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 to 

address specific concerns when we completed our project review. Such responses often generated more questions, frequently raising 

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 concerns 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 also 

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 contamination 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 2010. 

Soil samples were collected from 15 borings. The limited soil investigation identified additional soil contamination in the area. The 

contaminants in the soil were metals (primarily lead and arsenic), polynuclear aromatic hydrocarbons (PAHs), trichloroethene, vinyl 

chloride, trans-1,2-dichloroethene, and cis-1,2-dichloroethene. Soil samples for laboratory analysis were taken at depths ranging 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 groundwater 

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 accordance with requirements of Wisconsin’s Hazardous Substances Spill Law, sec. 292.11, Wis. 

Stats. and Chapter NR 700, Wis. Administrative Code. It is DNR’s understanding that unsuitable geotechnical fill will be removed 

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

As to procedural requirements of NR 150 for this EA Amendment 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 review process. Public comments provided 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 original 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 to the 

pre-existing industrial uses at the Domtar site only minor excavation 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 air 

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 emissions 

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 following 

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. 
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Table 1a. Criteria Air Pollutant Emissions (including regulated 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 
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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 

CO2 equivalent basis 

Tons per Year on a 

CO2 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 been completed, as outlined below. The first section provides the

analysis completed for the air pollution control permit. The second section contains an additional analysis for specific receptors and 

the air quality index review. The third and final section contains a risk analysis for selected hazardous air pollutants. The second and 

third sections are analyses not typically conducted for air pollution control permits, rather are additional analyses conducted for 

purposes of responding to numerous public inquiries regarding the proposed project to be included within this environmental analysis. 

The DNR uses dispersion modeling to evaluate the ambient air impact of air pollution sources. The following is a brief description of 

how that process works. 

A model is a mathematical simulation, designed to predict what can or will happen in real-world scenarios. Atmospheric dispersion 

modeling is useful in predicting the impact a particular facility will have with respect to a given pollutant. The major benefit of 

dispersion modeling is that it is an inexpensive 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) standards, both federal and state. 
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Dispersion modeling incorporates information about a facility, such as source/stack parameters, facility layout information, and 

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 result of 

(besides other factors) inversions. The pollutant concentration at the point of highest impact is added to a previously 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. 

According to the findings of the air quality analysis (air dispersion modeling) under permit action 10-SDD-058, the emissions from 

the facility (and nearby sources that contribute to impacts) will attain and maintain the NAAQS, which are set to protect public health 

and welfare. Those standards (NAAQS) are set at levels such that the most susceptible populations (children, elderly, and people 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, biomass boiler ash handling equipment, and a new cooling tower. Under

the Prevention of Significant Deterioration (PSD) program in Wis. 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 (NOX), particulate matter (PM/PM10), and particulate matter less 

than 2.5 microns in diameter (PM2.5). In addition, emissions of lead (Pb) were also modeled. 

Air quality impacts are assessed through an air quality dispersion modeling analysis. In addition to the proposed facility, several 

additional sources were included as they may provide additional impact in the area of the proposed project. The additional sources 

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 control permit. 

While emissions from diesel exhaust specific to this facility/project are not directly included in an air quality dispersion modeling 

analysis, they are indirectly through inclusion of background. Diesel 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 emission 

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 Analysis 

in support of a PSD Permit Application for WE Energies - Rothschild (Marathon County)’ Correspondence/Memorandum (refer to 

Attachment C), ambient air quality standards will be attained and maintained for TSP, PM10, PM2.5, SO2, NO2, and CO, and the PSD 

Class II increments will be protected for PM10, SO2, and NO2. 

Location 

WE has its operations along a water contributory just south of Lake Wausau in the Village of Rothschild, Marathon County. The area 

is currently in attainment for all criteria pollutants. PSD baselines in Marathon County for PM10 and SO2 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 parameters 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 meteorological 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 with AERMET, using the most representative land 

use data available. 
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The American Meteorological Society/Environmental 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 regulatory 

and non regulatory default options. These options allow for missing and calm wind correction, buoyancy induced dispersion, building 

downwash, recirculation cavity effects and internal computing of Ozone limiting values. 

Multiple grid configurations were considered and used, the largest of which being a rectangular grid of 9,971 receptors centered on the 

facility. Receptor spacing ranged from a minimum 25 meters to a maximum 1000 meters. The complete receptor grid consumed a total 

area of 514 million square meters (1.7 billion square feet). Terrain elevations were determined with AERMAP, using USGS National 

Elevation Dataset (NED). 

Fugitive based particulate emissions, including total suspended particulate (TSP), PM10 and PM2.5, 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 area 

of significant impact for the criteria pollutants, and it was discovered that concentrations for PM10, and 1-hour NO2 were above 

significant impact levels, so an increment analysis was performed. Additional increment consuming sources, other than those at WE 

exist in the area. The maximum impact of all the increment consuming 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 attain and maintain NAAQS for PM10, 

and 1-hour NO2, and will satisfy Wisconsin’s ambient air quality standards 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 result of 

associated growth, are expected. 

Visibility Impairment Analysis

Any facility emitting SO2, PM/PM10, and/or NOX 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 modified 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 National 

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 evaporation. A visible steam plume can be expected to occur when ambient 

air temperatures are relatively low with respect to plume temperature, thus promoting plume cooling and condensation, and ambient 

humidity levels are relatively high, preventing evaporation of the water in the plume. The persistence of the plume is dependent 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)’ Correspondence/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 (Marathon 

County)’ Correspondence/Memorandum (refer to Attachment C) are met. 
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Table 2a: Wisconsin Regional Background Concentrations 

Wisconsin Regional Background 

Concentrations 

(All Concentrations in μg/m3) 

Pollutant Period Value 

TSP 24 hour 39.7 

PM10 24 hour 29.4 

PM2.5

24 hour 

Annual 

25.6 

8.7 

Pb Quarterly 0.01 

NO2 1 hour 60.0 

CO 1 hour 

8 hour 

950.5 

904.7 

Table 2b: Significant Impact Analysis 

SIL Analysis Results (All Concentrations in μg/m3) 

 

PM10 

24 hour 

PM10

Annual 

PM2.5

24 hour 

PM2.5

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 μg/m3) 

 

SO2

1 hour 

SO2

3 hour 

SO2

24 hour 

SO2 

Annual 

Project Impact 

(1st High) 7.3 5.9 1.3 0.1 

Sig. Impact 

Level 7.8 25.0 5.0 1.0 
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SIL Analysis Results (All Concentrations in μg/m3) 

 

NO2

1 hour 

NO2 

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: NO2 conversion is based on the Plume Volume Molar Ratio Method (PVMRM). 

Modeling results show concentrations that exceed the significant impact level for the following pollutants and averaging times, 24 

hour and annual PM2.5, PM10 and 1-hour NO2. An analysis comparing impact of the following pollutants against the NAAQS is 

required: 1-hour NO2, 24 hour and annual PM2.5, 24 hour PM10. 

An analysis comparing impact of the following pollutants against the PSD class II increment standard is required: 24 hour and annual 

PM10. 

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

Table 2c: Increment and NAAQS Analysis 

NAAQS 

Analysis 

PM10

24 hour 

Facility Impact 39.1 

Background 29.4 

Total 68.5 

NAAQS 150.0 

% of NAAQS 46 

NAAQS 

Analysis 

NO2

1 hour 

Facility Impact 58 

Background 60 

Total 118.0 

NAAQS 188.0 

% of NAAQS 63 

Increment Analysis 

PM10

24 hour 

PM10

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 

PM2.5

24 hour 

PM2.5

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 Gradient 

0 100 200 300 50

Me

Modeled Concentration Gradient

We Energies - Rothschild Biomass Project

- modeled impact includes emissions from We Energies Rothschild, Domtar, and Lignotech - background concentrations not included

The data shown on this 

have been obtained from v

sources, and are of varyin

reliability, and resolution. 

map is not an authoritat

source of information ab

ambient air quality o

air emission sources

January 2011

Concentration Leg

< 3031 - 5051 - 7071 - 9091 - 111

(μg/m ) 3
- 12 - 

B.2.2. Ambient Air Dispersion Modeling for Specific Receptors, and Air Quality Index Review 

Introduction 

This analysis examines the short term pollutant impact at discreet locations due to the operations of WE Energies. For this analysis 24 

hour TSP emission rates were used and compared against 24 hour PM10 standards. It is the opinion of WDNR that measuring the 

higher emission loading due to TSP against the more restrictive standard of PM10 on a short term basis (24 hour) represents an 

unusually dramatic worst case scenario. Additionally, this analysis focuses 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 and 

its conclusions and results are overly conservative. 

Location 

WE is located at 200 Grand Avenue, Village of Rothschild, Marathon 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 parameters submitted with the analysis were verified against those supplied 

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 meteorological 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 with AERMET, using the most representative land 

use data available. 

The American Meteorological Society/Environmental 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 regulatory 

and non regulatory default options. These options allow for missing and calm wind correction, buoyancy induced dispersion, building 

downwash and recirculation cavity effects. 

A single grid consisting of 5 receptors placed at locations deemed to be sensitive was used for this analysis. Terrain elevations were 

determined with AERMAP, using USGS National Elevation Dataset (NED). 

Fugitive based particulate emissions 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. 

NAAQS Analysis 

The maximum impact of all WE sources was considered for this analysis and will satisfy Wisconsin’s ambient air quality standards for 

total suspended particulates (TSP). The regional background concentrations for the criteria pollutants were derived from several 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 their Rothschild facility so long as the information provided for this 

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 μg/m3 
- 14 - 

Figure 2: Modeled Concentrations at Discrete Receptors 

 Beta

 Delta

 Gamma

 Alpha

 Epsilon

0 500 250

Met

Modeled Concentration at Discrete Receptors

We Energies - Rothschild Biomass Project

- modeled impact includes emissions from We Energies Rothschild, Domtar, and Lignotech - background concentrations not included- 24-hr standard is 150 ug

The data shown on this 

have been obtained from v

sources, and are of varyin

reliability, and resolution. 

map is not an authoritat

source of information ab

ambient air quality o

air emission sources

January 2011

Facility ImpaFacility Boun
- 15 - 

The following table displays the pollutant impact due to the proposed 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 of the air. 

This impact is the average level of pollutant we would expect to measure at a particular location by using an air sampling monitor. 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 air quality. It tells you how clean or polluted your air is. For the purpose of this analysis, the 

reported AQI is a hypothetical value, because the listed impact is a forecast and as such has not 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 μg/m3) 

 

24 hour PM10

(small particles) 

24 hour PM2.5

(very small particles) 8 hour CO 24 hour SO2

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 primary standard for the listed pollutants will be met provided the emissions 

rates, stack parameters and all other restrictions used in this analysis do not change. Therefore, the health of "sensitive" populations 

such as asthmatics, children, and the elderly will be protected. Additionally, the welfare of the public is also protected, including 

protection against decreased visibility, damage to animals, crops, vegetation, and buildings. 

B.2.3. Inhalation Risk and Non-Carcinogenic Effects Screening for Hazardous 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 potential 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 potential 

emissions. The non-carcinogenic impact is equal to or greater than the highest expected impact at the receptor based on potential 

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 Integrated Risk Information System (IRIS) web site or the California 

Air Resource Board (CARB). Table 5b lists the modeled high concentration and inhalation risk as determined by the department for 

the receptors indicated. The inhalation risk was obtained by multiplying the receptor concentration by the risk factors. 

The USEPA Class or "Weight of Evidence" criteria are a rating of the various hazardous substances describing how well established 
- 16 - 

the risks are. Those classified as "A" are known human carcinogens. 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 therefore 

important to include the assumptions used in the analysis. 

a. For cancer risk analysis, the assumptions used are that a person weighing 70 kilograms lives at the point of maximum impact for

70 years and breathes 20 m3

 of air per day. When human data on carcinogenicity 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 lower 

doses that are typical of human exposures. In addition, it is assumed 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 likely (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 bound 

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 and 

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 Inhalation Risk and/or Non-carcinogenic Impact 

Contaminant 

Emission 

Rate 

(pounds 

per hour) 

Annual 

Impact 

1 Hour 

Impact 

24 Hour 

Impact 

Risk 

Factor Risk Standard Sta

P

Antimony 6.00E-03 2.42E-05 12 24 Arsenic 1.80E-02 4.32E-06 4.30E-03 1.86E-08 AnBeryllium 1.00E-03 2.40E-07 1.40E-03 3.36E-10 0.02 AnCadmium 3.00E-03 7.20E-07 1.80E-03 1.30E-09 Chromium 1.70E-02 4.08E-06 6.85E-05 1.20E-02 4.90E-08 12 AnChromium,-hexavalent 3.00E-03 7.20E-07 6.85E-05 1.21E-05 Cobalt 5.00E-03 2.02E-05 0.48 24 Lead 3.80E-02 9.12E-06 8.68E-04 1.53E-04 Manganese 1.28E+00 5.16E-03 1.8 24 Nickel 2.60E-02 6.24E-06 2.60E-04 1.62E-09 Phosphorus 2.20E-02 8.87E-05 2.43 24 Selenium 2.00E-03 8.06E-06 4.8 24 Hydrogen-chloride 1.44E+01 3.46E-03 3.29E-01 746/20 1 houHydrogen-fluoride 8.00E-01 1.83E-02 246 1 Acetaldehyde 6.64E-01 1.59E-04 1.52E-02 2.20E-06 3.51E-10 4505 AnAcrolein 6.01E-02 1.37E-03 22.9 1 Benzene 3.36E+00 8.06E-04 7.80E-06 6.29E-09 Benzo(a)anthracene 5.20E-05 1.25E-08 1.19E-06 2.10E-07 Benzo(a)pyrene 2.08E-03 4.99E-07 1.10E-03 5.49E-10 Benzo(b)fluoranthene 8.00E-05 1.92E-08 1.10E-04 2.11E-12 Benzo(e)pyrene 2.00E-06 4.80E-10 4.57E-08 8.06E-09 Benzo(g,h,i)perylene 7.40E-05 1.78E-08 1.69E-06 2.98E-07 Benzo(j,k)fluoranthene 1.28E-04 3.07E-08 2.92E-06 5.16E-07 Benzo(k)fluoranthene 2.90E-05 6.96E-09 1.10E-04 7.66E-13 bis(2-Ethylhexyl)phthalate 3.80E-05 9.12E-09 8.68E-07 1.53E-07 Bromomethane 1.20E-02 2.88E-06 4.84E-05 93.2/5 24 hr2-Butanone 4.00E-03 9.60E-07 9.14E-05 1.61E-05 Carbon-tetrachloride 3.60E-02 8.64E-06 1.50E-05 1.30E-10 Chlorine 6.32E-01 2.55E-03 34.8 24 Chlorobenzene 2.60E-02 1.05E-04 1105 24 Chloroform 2.20E-02 5.28E-06 8.87E-05 5.30E-06 2.80E-11 1172 AnChloromethane 1.80E-02 7.25E-05 2478 24 
- 19 - 

Contaminant 

Emission 

Rate 

(pounds 

per hour) 

Annual 

Impact 

1 Hour 

Impact 

24 Hour 

Impact 

Risk 

Factor Risk Standard Sta

P

1,2-Dibromoethene 4.40E-02 1.06E-05 1.00E-03 1.77E-04 Total-Polychlorinated-biphenyls-(PCB) 6.00E-06 1.44E-09 1.37E-07 2.42E-08 Total-Equiv.-2,3,7,8-TCDD-(Dioxins) 2.00E-06 4.80E-10 3.30E+01 1.58E-08 An1,2-Dichloroethane-(EDC) 2.30E-02 5.52E-06 9.27E-05 2.60E-05 1.44E-10 971 AnDichloromethane 2.32E-01 5.57E-05 9.35E-04 4.70E-07 2.62E-11 4168 An1,2-Dichloropropane 2.60E-02 6.24E-06 1.05E-04 8318/4 24 hrEthyl-benzene 2.50E-02 6.00E-06 1.01E-04 10421/1000 24 hrFormaldehyde 3.52E+00 8.45E-04 1.30E-05 1.10E-08 Indeno(1,2,3,c,d)pyrene 6.96E-05 1.67E-08 1.59E-06 2.80E-07 2-Methylnaphthalene 1.28E-04 3.07E-08 2.92E-06 5.16E-07 Naphthalene 7.80E-02 3.14E-04 1258 24 4-Nitrophenol 8.80E-05 2.11E-08 2.01E-06 3.55E-07 Pentachlorophenol-(PCP) 4.08E-05 1.64E-07 12 24 Phenol 4.10E-02 1.65E-04 462 24 Propanal-(Propionaldehyde) 3.00E-03 7.20E-07 6.85E-05 1.21E-05 Propionaldehyde 4.90E-02 1.18E-05 1.12E-03 1.97E-04 Styrene 1.52E+00 3.65E-04 3.47E-02 6.13E-03 Tetrachloroethene-(Perchloroethylene) 3.00E-02 7.20E-06 1.21E-04 5.90E-06 4.25E-11 4069 AnToluene 7.36E-01 1.77E-04 2.97E-03 4522/400 24 hr1,1,1-Trichloroethane 2.50E-02 6.00E-06 5.71E-04 1.01E-04 Trichloroethene 2.40E-02 5.76E-06 9.67E-05 2.00E-06 1.15E-11 6449 AnTrichlorofluoromethane-(CFC?11) 3.30E-02 7.92E-06 7.54E-04 1.33E-04 Vinyl-Chloride 1.40E-02 3.36E-06 8.80E-06 2.96E-11 100 Ano-Xylene 2.00E-02 4.80E-06 4.57E-04 8.06E-05 Mercury 2.00E-03 8.06E-06 0.24 24 

Note: An annual, 1-hour or 24-hour impact is calculated when there is a corresponding standard and standard period available. A level of risk is 

corresponding risk factor available. 
- 20 - 

Conclusions 

Air quality impacts from hazardous air contaminants at the maximum point of impact and at sensitive receptors are expected to be low 

compared to existing state health based standards for acute and 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, Lignotech, and WPSC-Weston, in addition to the proposed facility. Refer to the Ambient Air 

Dispersion Modeling and Risk Analysis sections above for more information. 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 sources 

operate in compliance with their existing or proposed air pollution control permits. 

D. Conclusion for Air Impacts

Air quality impacts are expected to be within 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 considering enforceable permit requirements the proposed action is 

expected to achieve compliance with applicable air quality standards 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 it 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 is 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 environment that it 

constitutes a major action significantly 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 challenge this decision, you should know that the Wisconsin statutes and administrative rules establish time 

periods within which requests to review Department decisions must be filed. For judicial review of a decision pursuant to sections 227.52 and 227.53, 

Wis. Stats., you have 30 days after the decision is mailed, or otherwise served by the Department, to file your petition with the appropriate circuit court 

and serve the petition on the Department. Such a petition for judicial review must name the Department of Natural Resources as the respondent. 

To request a contested case hearing pursuant to section 227.42, Wis. 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 the 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, additional information related to listed issues/responses is provided 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 street 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 particle 

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 analysis from 

all these sources, we do not expect any exceedence of the national ambient air quality standards set forth to protect public health and 

welfare [ch. NR 404, Wis. Adm. Code]. Therefore the Department concludes that there is no need for any additional monitors for 

particulate matter, or any other air contaminant, for the local area within Marathon County. 

2. When the pollution from the WE Energies facility is added to the background pollution, 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 plant 

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 regulated by the proposed stationary source air pollution control permit. While emissions 

from diesel exhaust specific to this facility/project are not directly included in an air quality dispersion modeling analysis, they are 

indirectly through inclusion of background. Diesel 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 emission impacts and 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% cleaner? 

 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 specific 

emissions? 

DNR Response: 

The specific emission rates from the proposed 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 existing combustion units at Domtar that will 

be shut down upon start-up of the new WE Energies biomass boiler. Furthermore, the new biomass boiler will be of newer technology, 

operating at greater efficiencies with better emission controls, more stringent regulatory and operational limitations. When comparing 

the current actual emissions from the existing facility operations to those of the future actual (anticipated actual operational) emissions 

of the new facility (WE Energies) and then remaining operational 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); approximately 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 will be 

handled separately. To the extent possible ash material will be beneficially reused for agricultural soil conditioner or re-burned at other 

facilities. If not beneficially reused ash waste is planned to be disposed of at Marathon County Landfill, which currently accepts ash 

from Domtar. The county landfill’s monofill for ash disposal is currently nearing capacity but the county is in the planning process for 

landfill expansion. The county has indicated if wood ash from the new facility is similar to Domtar’s existing wood ash, it would be 

accepted at the landfill. The county landfill is licensed by DNR and has no outstanding enforcement issues. 

4. According to their application, they state once the plant is built, they will have 30% cleaner air. However, they also state when the 

plant pollution and the background pollution are added together, they will be at 99% of what is safe in a 24 hour period, according to 

the NAAQS. What I do not understand is either they are not telling the truth, or they are telling the truth and today, and everyday 

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 will 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 the 

preliminary determination for that permit action), the current impacts are as follows (% of NAAQS): 

Total Suspended Particulates (TSP): 98.2% 

PM10, 24-hr: 74.7% 

PM10, Annual: 48.0% 

SO2, 3-hr: 64.6% 

SO2, 24-hr: 83.8% 

SO2, Annual: 98.6% 

Note: impacts also included nearby sources that may have potentially added impact around Domtar. 

The following table represents the current potential (allowable) emissions from the Domtar facility (information from the preliminary 

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 proposed 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, that analysis uses future actual emissions from the 

proposed project. An air dispersion modeling analysis does not use actual emissions, but rather the potential (allowable) emissions that 

would be included in the air pollution control permit, which are typically much greater than the actual emissions. Dispersion modeling 

incorporates information about a facility, such as source/stack parameters, facility layout information, and 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 result of (besides other factors) 

inversions. The pollutant concentration at the point of highest impact is added to a previously determined background concentration 

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 still be 

similar in the resulting level of that impact. This is apparent by the facility layout, source/stack parameters, operational limitations and 

emission rates, which differ between the existing site operations and the future (proposed) site operations. 

In summary, the ‘30%’ cleaner air statement 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 out of the 

plant is lingering on the lot and in the community. Furthermore, we had air quality reports this year, when the air was stagnant, and 

like today, the pollution did not dissipate. How is justifiable to expose a elementary school across the street from the plant to all this 

pollution? How is it justifiable to expose a community to all this pollution? When it rains, the air is stagnant, or there is inverse air 

flow, the air will linger in the 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 listing 

500,000 tons of wood being burned as the 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 board 

meeting they were asked if the wood inside would be a fire hazard? Terry Charles stated it would not be because the wood is going to 

be moist. However, moist wood burns with less efficiency and they will need more wood to create the power they need. Is this 

figured into the amount of wood they will burn? They state the wood chips will be 45% water, which will be less efficient. They state 

they will not sample every load, but for the safety of the community they should, due to the level of pollution they are operating 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 emissions 

are based on several factors, including: fuel type and characteristics, emission factors, operational design and control equipment, and 

any enforceable operational and/or emission limitations. The conditions that demonstrate compliance with the NAAQS will be set in 

the air pollution control permit as enforceable emission limits, control device operations, operational parameters (fuel type and 

amounts used), among other requirements. Any future expansion or increase of production or combustion sought by the facility, above 

what may already be approved in a permit, may result in a new air pollution control permitting action, which would again analyze 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 permit 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. Do 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 landfills, 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 more 

recent air pollution control construction permit, permit #: 09-MHR-228. The preliminary determination made for those permit actions 

are available for review, and contain similar review characteristics, including air quality analysis (air dispersion modeling), and 

municipal solid waste compliance for multiple air contaminants including volatile organic compounds and hazardous air pollutants 

(both state and federal). 

The existing ash monofill at Marathon County Landfill has an approved 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 transfer 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 elementary school? Or a community? 

DNR Response: 

Emissions from the source have been shown to be in compliance with all air pollution control permitting regulations, when operated in 

compliance with the permit. Those emissions will meet standards set to protect public health and welfare, including such pollutants 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, semi trucks were hauling out some of the sludge waste from the paper 

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 combust only biomass or natural gas in boiler B01, and only 

natural gas in boiler B02. Biomass, as defined in the permit, means a resource that derives energy from wood or plant 

material or residue, clean solid wood waste 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 manufacturers 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 derived 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 produced, and the amount of moisture they will release 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 ambient 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 that 

can predict ozone concentrations based on VOC or NOx emissions from a source. The regulation of NOx and VOC emissions as 

currently drafted will limit the amount of ozone formation, and it is expected that there would be no risk for ozone issues as a result of 

this project. 

11. The amount of sulfur dioxide they put in the air will increase from 11.8 in the background they will put in 951 for a combined 

962.8 micrograms per cubic meter, which is 74% of what the NAAQS 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 admissions 

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 report 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 reported that this would add to the cost, forcing the 

power plant to seek other options to burn. Scott Madden also spoke about the pressure on pallet companies, paper industry, pellet 

makers, counter top producers, and the supply and demand issues from burning 500,000 tons of wood. In fact, this pressure I just 

spoke about was one of the reasons the paper industry people out of Green Bay opposed a plant in Ashland I believe. They stated 

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 comment 

#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 it is good. 

 However, according to the DNR and the state 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 fuel and 

estimated fuel and other costs. Additional studies were done to determine the distance range of an adequate supply of woody logging 

residue biomass to support a 50 megawatt generation facility. Studies concluded there was sufficient woody biomass available within 

75 miles to support the proposed facility. The Department has reviewed those studies and does not disagree with these findings, but 

we have not done independent confirmation studies. DNR has no authority 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 private 

woodlands in the anticipated biomass supply radius provide other important economic, social and environmental benefits. Examples 

are soil and watershed protection, wildlife habitat and ecological diversity, recreation and aesthetics. Less understood indirect benefits, 

such as carbon sequestration and its relationship to climate change, are also provided. According to PSC’s environmental assessment 

for this project 70-75% of Domtar-bound harvests are from federal/state/county forests, tribal forests and private lands enrolled in the 

state managed forest land (MFL) program. Management objectives/requirements of these forest lands is designed to protect all forest 

values (i.e. such as those noted above) in a sustainable manner. WEPCO, using Domtar as its biomass procurement agent, has stated 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 such ‘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 comment 13 above and in PSC’s EA as well, 

additional research and monitoring would be useful to help minimize the potential risk of woody biomass-fuel procurement impacts 

from this and future projects to protect forest/woodland values in a sustainable manner. To add emphasis to this point, the PSC EA 

also notes that the fuel-source radius for this project overlaps with that of other approved or planned woody biomass fueled energy 

generation facilities. Thus, while most (70-75%) of the intended fuel-source forest lands for the Rothschild facility have existing 

management programs in place consistent with sustainability concepts, there is an unknown threshold point at which available woody 

biomass can provide fuel for these types of projects. Future business start-up decisions using woody biomass as fuel will likely take 

this limited resource availability factor into account during project 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 released, 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 and 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 with 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, Ambient Air Dispersion Modeling and Risk Analysis’ section of the EA above. That section 

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 power 

plant. Please refer to the ‘Operational Impacts, Ambient Air Dispersion Modeling and Risk Analysis’ section for more information 
- 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 about 

380 gallons/minute (gpm) or 0.547 million gallons/day (gpd). During average operating conditions the combined biomass discharges 

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 have stated they will release "heated water" that is at a higher rate than what is currently 

being released into the river. What effect will this combined heated water have on the river? 

DNR Response: 

New administrative rules that establish water quality standards for temperature became effective October 1, 2010. Based on 

information provided by Domtar and WE Energies to date, it appears that water quality-based effluent limits for temperature will not 

be necessary when the standards are applied to Domtar’s wastewater discharges either at current flow rates or when flow rates are 

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 notifying the local, state and federal officials of a spill. We have a volunteer 

fire department in our community, should a spill occur, they do not have a clear plan to let the residents know about evacuation or 

what the potential problems could be. 

DNR Response: 

Prevention of spills by using proper 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 Emergency Planning and Community Right-to-Know Act (EPCRA) requires 

facilities to report to the local community if they have certain quantities of chemicals on hand. This law also requires facilities work 

with the fire departments and local emergency responders on developing 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 Federal Law to report to, submit and coordinate response plans with 

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 required to respond to minimize any harmful effects of the spill under State 

law, Chapter 292.11 Wisconsin Statutes. This laws enables the DNR to take action if the responsible party is unable or unwilling to 

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

DNR Wardens work directly with local emergency responders on spills. DNR can assist local responders, hire contractors to respond 

if necessary, and has a working relationship with USEPA and other federal agencies should Federal assistance be required. Contact 

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 semi 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 where they say they will operate, I feel there are too many questions 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 followed by a subsequent decision whether or 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. 

22. Our current air quality is poor. In 1999, per the EPA, Marathon County was rated among the worst 10% of all counties in the 

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 counties in the US in terms of an average individual'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 will 

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 Impact Statement related to this proposed biomass facility. For the 

children at the elementary school across 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 or 

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 pollution 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 pollutant emissions on health, welfare, and the environment, federal and state laws are implemented 

to reduce emissions to levels that research has shown would protect the majority of individuals and reduce overall impacts on ecosystems. 

 The U.S. Environmental Protection Agency (EPA) has established National Ambient Air Quality Standards (NAAQS) to regulate the 

emissions of six “criteria” pollutants: carbon monoxide (CO), nitrogen oxides (NOx), ozone (O3), lead, particulates (PM, PM10, PM2.5), 

and sulfur dioxide (SO2). The standards are based on EPA’s interpretations of health impact research related to those pollutants. The 

NAAQS levels are set by EPA with the intent to protect not only the general population, but also so-called “susceptible populations,” 

individuals with asthma, young children, and the elderly. To achieve this level of protection, EPA requires that modeling for new 

facilities’ air pollution control permits be performed at the maximum allowable emission level that would be permitted. The required 

emission level for the modeling to obtain a permit would be a level that could never be realized in actual operation. The requirement 

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 criteria pollutants 

require a different approach than the others. Ozone is generally controlled by controlling the emission of nitrogen oxides (NOx) and 

volatile organic compounds (VOC) that react with NOx to form O3. PM2.5 particles are emitted directly and are formed chemically in the 

atmosphere, mostly from NOx and SO2. 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 discussed 

below in Section 2.2.1.4. 

The criteria pollutants are controlled mostly by application of Best Available Control Technologies (BACT) that bring each pollutant’s 

level below a certain limited emission rate. The company has proposed control technologies, and DNR will approve or modify them after 

doing its own modeling and analyses. 

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

 For SO2, BACT appears to be the CFB plus the use of low sulfur biomass fuels. 

 For PM and PM10, BACT would be a fabric filter baghouse and, for PM2.5 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 operation permits from DNR. DNR review of the air permit applications 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 criteria pollutants would be 100 tons or more per year after 

controls. DNR is preparing an EA before action on the air 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 retirement of the existing Domtar boilers would result in a decrease in 

overall emissions by about 30 percent. It provides two tables in the project application Technical Support Document1

 that add up the 

measured tons per year of criteria pollutants emitted from Domtar’s existing boilers and the estimated tons per year expected from 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 highest modeled air concentrations at any receptor 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 lead4

) 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 Rothschild 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 Rate6 (tons per year) 

Estimated Maximum Allowable Emissions for 

Entire Proposed Project, Representing BACT7

(tons per year) 

NOx 396 172 372 

CO 230 218 766 

SO2 1.4 5 316 

PM and PM10 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/m3) for the pollutants over certain established 

averaging periods during which they have been shown to have effects. EPA-defined SILs currently exist for PM10, CO, SO2, and the 

annual NO2 NAAQS, again based on interpretations of health impact research related to those pollutants. It is EPA’s policy to exempt 

proposed pollution sources from conducting comprehensive, 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 respective SIL, 

it is presumed that the project will not cause or significantly contribute to a PSD increment or NAAQS violation. For this reason, the 

project applicant would not be required to perform multiple source cumulative impact assessments for that particular pollutant. 

Exceeding those SIL concentrations, however, triggers a NAAQS air dispersal analysis. WEPCO’s application shows SILs not exceeded 

for: 8-hour and 1-hour concentrations of CO; annual concentrations of NOx; and annual concentrations of SO2. Because their SILs were 

not exceeded, those pollutants and averaging intervals were not pursued by the company in the cumulative dispersion modeling analysis. 

Those pollutants and averaging intervals where concentrations exceeded the SILs were carried through the NAAQS analysis.8

Table 4 summarizes the pollutant dispersion modeling results and how the resulting air concentrations approach the NAAQS, as provided 

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, Table 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 PM10 appeared in the CA application and air permit application to exceed the SIL. Annual PM10 is not included in 

the modeling because the state Natural Resources Board adopted the PM2.5 NAAQS and repealed the annual PM10 NAAQS in 2009. 9

 Information provided by WEPCO in Technical Support Document, pages 62- 64, Table 2.18-10; and Prevention of Significant Deterioration 

Air Pollution Control Construction Permit Application, pp. 51-54, Table 7.3. “Cumulative impacts” include air concentrations resulting from 

the proposed sources plus existing nearby sources as provided by DNR. 
- 32 - 

Table 4 WEPCO’s estimated expected cumulative air concentrations and existing background concentrations of criteria 

pollutants compared with NAAQS, in micrograms per cubic meter (g/m3

) 

Pollutant Averaging 

Interval 

Cumulative 

Concentration 

Impact 

Background 

Concentration 

Total 

Concentration NAAQS Percentage of NAAQS 

NOx 1-hour 61 12 73 188 39% 

SO2 24-hour 249 11 260 365 71% 

SO2 3-hour 951 12 963 1300 74% 

PM10 24-hour 42 29 71 150 47% 

PM 2.5 Annual 2 9 11 15 73% 

PM2.5 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 algorithms 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 quality than the 

maximum allowable stack emission numbers shown in Table 3. Also, the modeled air concentrations in g/m3

are based on all the 

allowable emission rates in the area and the dispersion modeling algorithms, so there is no direct correlation between the allowable 

emissions in tons per year, or expected emissions in tons per year, and the maximum predicted air concentrations in g/m3

. As can be 

seen in Table 4, TSP and PM2.5 would reach concentrations within 96 and 99 percent of their NAAQS, respectively. These expected 

concentrations are close to violation of the NAAQS and might likely be the most logical pollutant situations to watch during plant 

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 that may 

influence this apparent discrepancy.10 The modeling previously done for 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 operational 

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 rigorous, 

modeling software (AERMOD). The differences in the facility layout, stack locations and parameters, and allowable emission rates or 

operational factors for the proposed units would all play a role in how the impacts might change and whether they might increase, 

decrease, or stay relatively the same. Therefore, it is not a one-to-one comparison based solely on emissions. Furthermore, the 

WEPCO-projected 30 percent reduction appears to be accounted on the actual emissions. “Actual” emission differs from the emissions 

utilized in an air dispersion model. The model utilizes “allowable” emission rates, which are normally much higher than expected or 

actual emissions. DNR staff point out that no direct comparison can be made between the projected 30 percent reduction in expected 

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 greater than the NAAQS is designated as a non-attainment county. Along 

with the obvious public health concern, being designated non-attainment may have an adverse impact on economic development of an 

area. Any major modification or major new emissions source would have to install the very best control equipment and find offsets for 

new emissions. DNR has anecdotal evidence suggesting that industrial sources looking to expand appear to avoid designated 

non-attainment areas.11

Regardless of whether the facility’s emissions meet the NAAQS, there is often a question of whether more sensitive individuals are 

adequately protected. In general, when air pollution levels increase, sensitive individuals might experience adverse respiratory symptoms. 

 The most vulnerable members of a population are generally the young, the elderly, and the infirm. Members of the public who are most 

susceptible to environmental stress can often be found in hospitals, schools, daycare centers, and retirement homes. Two elementary 

schools are located just over a half mile to the north and east of the project site. At least one, Rothschild Elementary School, 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 president wrote last year to U.S. Representatives Henry Waxman and Edward 

Markey, commenting on their legislative initiative for address global climate change and energy policy, and stated that, 

 

10 Private communication with Jeffrey Johnson, 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 promote the combustion of biomass. Burning biomass could lead 

to significant increases in emissions of nitrogen oxides, particulate matter and sulfur dioxide and have severe impacts 

on the health of children, older adults, and people with lung diseases.”12

Again, the NAAQS are based on EPA’s interpretations of scientific health impact research related to those pollutants. Their purpose at 

EPA is to protect not only the general population but also susceptible 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 classification of pollutants known also as toxic air pollutants or air toxics under the Clean Air Act. 

The Clean Air Act requires EPA to reduce the routine daily emissions of air toxics first by a technology-based approach, and EPA has 

created Maximum Achievable Control Technology (MACT) standards for 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 standards are enforced under the Clean Air Act (and Wis. Admin. Code ch. NR 

445) as case-by-case MACT for projects that would reach threshold levels qualifying them as “major sources.” The emission of each 

HAP is being modeled by the DNR Air Bureau and adjusted to limits 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 Act13 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 thresholds. WEPCO offers four categories of HAPs expected to be emitted 

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 year to 

qualify it as a major source of HAPs. WEPCO has applied case-by-case 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 discussed 

below. The CFB would be classified as an industrial boiler because it would not combust fossil fuels in greater than a threshold amount. 

Inorganic solid phase HAPs, including heavy metals of concern, are listed in Table 5 and proposed in the company’s permit application 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) and hydrogen fluoride (as HF) and are also to be controlled with 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 gas and 

about 4 tons per year of HF gas. Recently-published EPA-proposed industrial boiler MACT rules require the new MACT standard for 

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 because they 

were indicated to be emitted in absolute amounts even if their potential emissions round off to 0.0 tons per year to the nearest 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 than the 

 

12 Charles D. Connor, President and CEO, American Lung Association, letter to U.S. Representatives Henry Waxman and Edward Markey. 

June 24, 2009. 

13 Section 112(b) of the Clean Air Act. 
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inorganic solid phase HAPs and include the individual HAPs that triggered the case-by-case MACT requirement (bolded in the table). 

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 expected 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 the CFB boiler, in tons per year rounded to the nearest tenth 

of a ton14

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 Trichlorofluoromethane (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 permit 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 estimates 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 original air permit application to 52.7 tons per year. This total 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 particularly under Wis. Admin. Code ch. NR 446 but also subject to case-by-case 

MACT. Mercury may be an issue with tree bark because trees have taken it into their systems. Currently, over 300 Wisconsin lakes and 

river stretches carry fish consumption advisories for mercury. Mercury accumulation in fish-consuming wildlife can lead to reproductive 

problems. Human consumption of fish that contain mercury can damage the nervous system, especially in children and fetuses. Mercury 

emissions may not exceed 2.9 pounds per trillion Btu from the boiler. CFB emissions of mercury would be controlled with the fabric 

filter baghouse according to the WEPCO air permit application. EPA recently proposed national emission standards for control of 

 

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 Governor and 

DNR Secretary submitted comments to the EPA on its proposed industrial boiler MACT rule, requesting revisions to the EPA’s approach to 

MACT for biomass boilers. It is possible that the final industrial boiler MACT rule will include different standards for biomass-fired plants 

than those included in the proposed MACT standard. Estimated levels for organic HAPs with currently proposed MACT standards that 

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 Construction Permit, on HAPs, was revised 7/9/2010. PSC REF #134769. 
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mercury emissions from biomass-fired area source boilers and for other hazardous air pollutants based on EPA’s proposed determination 

about what constitutes the generally available control technology or management practices. DNR is planning to use the EPA-proposed 

biomass MACT as MACT for the proposed boiler, unless WEPCO shows how it does not represent new source MACT for the project.16 

The recently-published EPA-proposed industrial boiler MACT rules include an updated MACT standard for mercury. With that update, 

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 combustion. 

 According to WEPCO’s air pollution permit application, and as seen in Table 6, dioxins and furans would be produced. Trace amounts 

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 through 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 recently-published EPA-proposed industrial boiler 

MACT rules include updated HAP limits for some MACT standards, including that for dioxin/furan emissions. The dioxin/furan MACT 

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 appears 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 from the 

CFB boiler would be minimized by good boiler design and good combustion control, which minimizes precursor formation. This control 

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

Applying the emission limits from the EPA’s proposed industrial boiler MACT standards, potential dioxin/furan emissions from the CFB 

boiler would be 0.00000031 pounds per year (or 310 billionths of a pound). WEPCO must compare this emission rate to the most toxic 

members of the category: 2,3,7,8-tetrachlorodibenzo-p-dioxin and 1,2,3,7,8-pentachlorodibenzo-p-dioxin. The comparison is stated as 

Toxic Equivalency (TEQ). DNR’s threshold emission rate for dioxins and furans under Wis. 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 threshold 

amount for DNR regulation under Wis. Admin. Code ch. NR 445. So, expected potential dioxin and furan emissions would be far below 

the threshold level that would require regulation 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 NOx control 

system. In its air permit application, WEPCO estimates ammonia emissions from the stack to be about 122,303 pounds per year (about 

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 and 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 baghouse to 

remove particulates before being exhausted to the atmosphere. According to Appendix C of the air pollution control construction permit 

application,18 emissions of PM and PM10 are estimated to be controlled to about 16 tons per year each and emissions of PM2.5 would total 

about 8.2 tons per year. These levels might be lower after the company and DNR refine the expected emissions while DNR processes 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 unloading 

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 would have vent filters, as would the ash handling and storage silo system. 

WEPCO also proposes to pave all roadways and use dust suppression on roads when necessary as BACT to control fugitive dust. The 

company expects that this would reduce dust by about 85 percent over doing nothing. The company estimates emissions of PM2.5 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 PM10 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 otherwise 

 

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-related correspondence to date has been filed as a supplement to

Technical Support Document Appendix G, State Permits, Notices and Approvals (PSC REF #132184).
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would be about 1.417 tons per year on biomass delivery truck 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 evaporate. 

The company indicates that PM emissions would be at about 0.386 tons per year, PM10 emissions would be at about 0.317 tons per year, 

and PM2.5 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 during operation. Potential impacts of GHG emissions on global climate change and its potential 

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 Programme to provide an objective source of information about global 

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 (CO2) and nitrous oxide (N2O), which would comprise most of the GHG emitted from the CFB boiler, are discussed in 

this subsection.21 Other GHGs include methane (CH4) and fluorocarbons. In response to staff data requests, WEPCO provided 

information about GHG emissions with the caveat 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 CO2 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 relatively 

new Weston Unit 4 supercritical pulverized coal-fired boiler. WEPCO points out that the commonly recognized difference between a 

biomass and coal plant is that carbon released from combustion of biomass is presumed to be absorbed or “resequestered” by other 

biomass as it grows, making the biomass plant “carbon neutral.” A discussion of the carbon neutral argument is below. In Table 7, the 

emission levels are shown in tons per year and CO2 equivalents (CO2e). The global warming potential of N2O emissions is 310 times that 

of CO2, so N2O emissions are also given as CO2e. 

Table 7 WEPCO estimates of CO2 and N2O emissions in tons per year from the proposed project, including N2O as CO2

equivalents 

CFB Boiler Emission Natural Gas Auxiliary Boiler 

Emission Greenhouse 

Gas Tons/yr emitted Tons/yr CO2e Tons/yr emitted Tons/yr CO2e

Diesel Feedwater 

Pump Emission 

CO2 590,000 590,000 13,000 13,000 17 

N2O 39 12,090 0.2 62 - 

Total CO2e 602,090 13,062 17 

Adding up total tons per year in CO2e from the plant results in a total of 615,169 tons of CO2e. 

Commission engineering staff has performed modeling analyses on several generation alternatives to this plant using the following 

assumptions: 

 the CO2 emissions would be five percent greater than WEPCO’s estimate to account for the presence of running diesel trucks on 

the plant site 

 the N2O emissions would be twice the amount estimated by WEPCO because of uncertainties related to the choice of a CFB 

boiler 

The intervener SOAR has suggested that the additional impact of N2O emissions on the total CO2e should be notably greater, but 

WEPCO’s information and Commission engineering staff adjustments both seem to result in N2O emissions being a small percentage of 

the total CFB boiler emissions. If WEPCO’s estimated N2O emissions from the CFB boiler are included in CO2e, the amount of CO2e

from the CFB boiler increases by approximately two percent. If they are doubled, as in the engineering staff modeling, the amount 

 

19 For example, Climate Change 2007: Synthesis Report. Contribution of Working 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 N2O is an oxide of nitrogen, it is not a criteria pollutant. Wis. Admin. Code § NR 400.02(107) defines NOx as “all oxides of 

nitrogen except nitrous oxide.” 
- 37 - 

increases by approximately four percent. If the CO2 emissions are increased by five percent to account for trucks as part of the CFB 

emissions, the total CO2e emitted increases to 619,500 tons but the doubled emission estimate of N2O would still be approximately four 

percent of the CFB CO2 output. 

The final determination of N2O and CO2e emission limits will, as discussed below, be part of the DNR air pollution control permit. 

The following discussion is primarily based on CO2 or its surrogate term, “carbon.” 

GHGs, including CO2, 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 tons of GHGs per year in CO2e

would be required to obtain a permit with BACT and comply with existing PSD regulations for CO2e 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 permit, 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 permitting. The Tailoring Rule set the threshold for GHG emissions as 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, but the 

biomass industry is striving to effect rule changes that would avoid disincentivizing biomass power.22 The EPA has issued a Call for 

Information23 that serves as a first step in considering separate options for addressing emissions of biogenic CO2 under the PSD and Title 

V programs. The Call’s purpose is to request comments on how a different approach for biomass plant emissions might be developed 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 develop possible accounting approaches. 

In Wisconsin, the regulation of GHG emissions by the EPA will be done through the state DNR air pollution control permitting process. 

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 threshold under the pending federal law and require the company’s air permit to apply BACT as of 

January 2011. 

At the time of preparation of this EA neither CO2 nor N2O are regulated under the Clean Air Act or Wisconsin Administrative Code. 

There are no specific control requirements for the proposed CFB boiler and no other similar facility available for comparison that 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 released 

from combustion of biomass is presumed to be absorbed or captured by other biomass as it grows. No clear declaration of Wisconsin 

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 does not appear to consider biomass combustion to be carbon-neutral at this 

time. 

The concept of “carbon neutral” in this context may be more complicated than recognized at first glance. The GWTF’s Biomass and 

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 future of biomass.” Greenwire. June 9, 2010. Bravender, Robin. 

“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 Review 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 
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The recent report by the Manomet Center for Conservation Sciences, commissioned by the state of Massachusetts, cites the 2009 status 

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 biomass harvest and use options is “complicated by the fact that the 

performance of the different options is site-specific and is determined 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 would 

be used; 

 The fossil fuel system that would be replaced; 

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

 The timescale being considered for sequestration. 

According to WEPCO, CO2 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 cogeneration plant because the fuel would change 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 CO2 emissions from 

a biomass plant should be considered to be a net level 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 CO2 emitted 

by the proposed project. If compared to the timescale required for sequestering the amount of CO2 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 CO2 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 woodland 

timber rotting slowly over decades. 

Several factors could affect the relative levels of CO2 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 combustion, for 

example, the regenerating forest would need to grow to the maturity level of those harvested whole trees in order for the system to 

approach a carbon neutral state. If the biomass burned at the Domtar cogeneration plant were entirely harvest residues, the regenerating 

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 CO2 sequestration life 

cycle.29

When the entire carbon cycle is examined, additional CO2 emissions during harvest, transport, and handling are considered. There also 

would be some CO2 production from machinery operation related to the boiler and fuel handling. Research identified so far indicates that 

precise estimates of CO2 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, the types of landscapes harvested, and the distance from each biomass source to the power plant.

The CO2 emissions related to hauling the biomass to the plant can be estimated. The U.S. Department of Energy’s Energy Information 

Administration estimate of CO2 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 application, WEPCO says that there would be an additional 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 CO2 emissions from trucks delivering biomass to the plant from 75 miles away would be about 

6,552 tons of CO2 per year if those 75 trucks per day delivered fuel on weekdays 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 Conservation 

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 CO2 per gallon of fuel burned. This figure, 6,552 tons of CO2 from fuel hauling, is quite small (just over 1.0 

percent) compared to the annual CO2e 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 limit range for biomass fuel (a worst-case scenario), and 

because more fuel would likely be harvested and delivered from less than that distance, an average hauling distance could be about 37.5 

miles. Using the 75 trucks-per-day estimate for trips and the fuel consumption values above, the CO2 emissions from trucks delivering 

biomass to the plant from 37.5 miles away would be about 3,276 tons of CO2 per year. This figure is only about 0.5 percent of the 

amount of CO2e emissions that would be released from the CFB boiler. 

An estimate of CO2 emitted during harvesting and chipping at the logging site is more difficult to obtain at this point, but it could be in the 

same range of emission levels. Thus, it appears that while the CO2 emissions associated with harvesting, hauling, and conveying the 

biomass to the boiler on the plant site are part of the carbon life cycle emissions of biomass, these values are quite small (less than 3.0 

percent) in comparison to the amount of CO2 emitted during the combustion process. These CO2 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 estimates 1,000 truckloads of ash from the CFB each year. 

Burning diesel fuel to haul the ash is a necessary activity related 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 intends to 

truck it to either Pleasant Prairie in Kenosha County or the Elm 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 CO2

emitted by ash trucks per year if it is spread locally in Marathon County or nearby. If all the ash was trucked to Pleasant Prairie or Elm 

Road, about 895 tons of CO2 would be emitted annually. This figure is about 0.1 percent of the CO2e expected to be emitted from the 

CFB boiler, a relatively small contribution. 

The residue from logging that would not be harvested for the cogeneration plant would degrade over time as it decayed on the forest floor, 

releasing CO2, and methane, another GHG gradually without the relative bursts of CO2 emissions from combustion in the boiler. 

2.2.1.5 Truck emissions 

CO2 emitted from trucks hauling biomass is discussed in the previous section. However, diesel exhaust includes much more than GHGs. 

People living in the project area have expressed concern about air 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 entrance would decrease and consequently, so would truck emissions. In the 

Rothschild area overall, biomass fuel delivery, ash hauling, and delivery of power plant chemicals would contribute to increases 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 distance of 

about 1.8 miles. (Potential truck traffic impacts are described further in Section 2.2.4.) 

Diesel exhaust is composed of two phases, gas or particle. The gas phase is composed of several urban hazardous air pollutants, such as 

acetaldehyde, acrolein, benzene, 1,3-butadiene, formaldehyde, and polycyclic aromatic hydrocarbons. The particle phase also has many 

different types of particles, varying in composition but mostly classified by size. The sizes of diesel particulates of greatest 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 evidence 

indicating that inhalation of diesel exhaust causes acute and chronic health effects. Acute effects could include irritation to the eyes, nose, 

throat, and lungs, some neurological effects such as lightheadedness, and a cough or nausea or exacerbation of asthma. Diesel particulate 

is classified by EPA as a suspected human carcinogen. One could assume that cancer is a non-threshold process where even a very small 

amount of carcinogen has some level of risk associated with it. Human epidemiological studies have shown an association between 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 residents and 

 

31 This attachment is adapted from “Map 2,” a staff-produced attachment 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. 
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students in Rothschild would not be in an occupational setting 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 SO2 emissions 

from truck traffic negligible. On the project site, trucks would 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 emission 

estimates for the plant site are given in Table 8, based on the projected 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 delivery truck emissions on the cogeneration plant site in tons per year 

Pollutant Annual Emission Rate 

Increase (tons per year) 

NOx 0.21 

VOCs 0.006 

CO 0.04 

PM2.5 0.30 

It is probable that more than one truck would be at the weigh scales 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 idling.35 

While the emissions resulting from following the path from the entrance to the unloading area maybe be relatively low, it may still be 

appropriate to limit the amount of truck engine idling at the Rothschild plant as deliveries wait to be unloaded. This could be done by 

having a truck idle no longer than a certain number of minutes before the engine must be turned off. Or, it could be done by limiting the 

numbers of trucks, through scheduling and dispatching, that could be on the property waiting to unload. EPA indicates that, to minimize 

risk, it would be helpful if the trucks were required to avoid unnecessary idling by turning off the engine when the truck is not in motion. 

Operators could also be encouraged or required by the company to keep their vehicles in proper condition. And, there are pollution 

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

WEPCO states that trucks would be shut down when they are being unloaded. Trucks waiting to unload would queue in the road between 

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, south of the truck dumpers and north of the biomass storage building. WEPCO states that it is 

likely that the trucks would idle while they wait to be weighed and unloaded, but also that waiting could be minimized by having 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 sources like 

delivery trucks. Emissions from truck traffic are included in the air permit modeling only as part of the background concentrations.37 It is 

not likely that projected truck traffic would be included because it would not be measurable until the project was approved and operating. 

 However, it appears that cumulative increase in PM2.5 emissions related to the projected amount of truck emissions would be a relatively 

small when compared to the projected amount of PM2.5 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 PM2.5 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 PM2.5 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 large 

enough to cause the proposed project to exceed NAAQS. 

Considering mobile sources, EPA has a “hot spot” analysis model for looking at high-truck-traffic projects. The traffic threshold for 

needing such an analysis for air pollution impacts is relatively high. The analysis is used mainly for new truck terminals, freeways, 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 truck 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. 
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arterials in nonattainment areas. DNR staff indicates that the Rothschild plant would not likely meet the threshold for such an analysis.38 

 An example situation that would be covered by this federal law39 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) where eight 

percent or more of the AADT (at least 10,000 vehicles) is diesel trucks. An example of a recent analysis for an indirect source air permit 

was done for a Roundy’s Supermarkets, Inc. (Roundy’s) proposal to build a large distribution center in Waukesha County. The center 

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 arrivals so that no 

trucks entered the facility more than four hours prior to or one hour after an arranged appointment time. 

Because the major increase in truck traffic at the south entrance would be for biomass 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 delivery truck emissions on Business USH 51 between STH 29 and I-39 in tons per 

year 

Pollutant Annual Emission Rate 

(tons per year) 

NOx 0.96 

VOCs 0.03 

CO 0.18 

PM2.5 0.21 

Some comparison between the estimated pollutant amounts on Business USH 51 and the existing air pollution situation on that stretch 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 roads 

used in biomass delivery, WEPCO used the DNR model and EPA emission factors to estimate current emissions from all traffic on this 

triangle for comparison. Its summary, showing emissions in pounds per day, is shown in Table 10. Again, GHGs and SO2 were not 

included. 

Table 10 WEPCO’s estimated current vehicle emissions and future 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 

NOx 19 792 2.4% 

VOCs 1 295 0.3% 

CO 4 3497 0.1% 

PM2.5 4 142 2.8% 

This information indicates that none of these pollutants, including volatile organics and fine particulates, would increase beyond 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). 
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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/amexternal/AM_PermitTrackingSearch.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.’ field. [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 Documents’ 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, including the Preliminary Determination and the air dispersion 

Modeling Analysis report.