STATE OF MICHIGAN
Rick Snyder, Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
CONSTITUTION HALL ● 525 WEST ALLEGAN STREET ● P.O. BOX 30260 ● LANSING, MICHIGAN 48909-7760
www.michigan.gov/air
PUBLIC PARTICIPATION DOCUMENTS
For
Frontier Kinross, LLC
Kincheloe, Michigan
PERMIT APPLICATION NUMBER
166-09A
May 16, 2011
Frontier Kinross, LLC
Permit No. 166-09A
Page 1
May 16, 2011
FACT SHEET
May 16, 2011
Purpose and Summary
The Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), is
proposing to act on Permit to Install (PTI) application No. 166-09A from Frontier Kinross, LLC
(Frontier). The permit application is for the proposed installation and operation of a 40 million
gallon per year wood-to-ethanol facility with a 535 MMBtu/hr bubbling fluidized bed biomass
boiler to provide electricity, steam, and hot water for the facility. The proposed project is subject
to permitting requirements of the Department’s Rules for Air Pollution Control. Prior to acting on
this application, the AQD is holding a public comment period and a public hearing, if requested
in writing, to allow all interested parties the opportunity to comment on the proposed PTI. All
relevant information received during the comment period and hearing if held, will be considered
by the decision maker prior to taking final action on the application.
Background Information
On September 15, 2010, after a public comment period and public hearing, the AQD approved
Permit to Install No. 166-09 authorizing Frontier to install and operate a wood-to-ethanol facility
to produce up to 42.5 million gallons per year of fuel grade ethanol (denatured with 5%
gasoline).
On April 18, 2011, Frontier submitted Permit to Install Application No. 166-09A for a variety of
changes to the facility design, including replacing the six natural gas fired boilers with a single
biomass boiler. The AQD reviewed Permit to Install Application No. 166-09A as a brand new
facility rather than a modification of the currently permitted facility.
Proposed Facility and Present Air Quality
Frontier is proposing to receive whole logs and debark and chip them. The bark will be stored in
a silo and either burned in the on-site boiler or sold as a product. Frontier is also proposing to
receive wood chips. The wood chips will be stored in silos and mechanically conveyed to a pretreatment process to prepare them for fermentation. The treated feedstock will then be
transferred to the fermentation system. The total wood throughput is expected to be 562,100
bone dry short tons per year.
The product of the fermentation system will be distilled to separate the ethanol from most of the
water and the residual solids. The distilled ethanol/water mixture will go through molecular
sieves to produce pure ethanol, which will be mixed with a denaturant (gasoline or natural
gasoline) to produce denatured ethanol (95% ethanol, 5% denaturant). There are six storage
tanks; three 120,000 gallon tanks for pure ethanol, two 600,000 gallon tanks for denatured
ethanol, and one 45,000 gallon tank for denaturant. The denatured ethanol will be loaded into
tanker trucks or rail cars for shipment to the final customers. The proposed permit limits
combined ethanol and denaturant throughput to 42.5 million gallons per year and limits
denaturant throughput to 2.5 million gallons per year.
The water and solids from the distillation process will be separated using centrifuges and a
multi-effect evaporator train. The water from the evaporator will be treated in a methanator that
will produce methane and biosolids, which will be burned in the on-site boiler. The centrifuged
Frontier Kinross, LLC
Permit No. 166-09A
Page 2
May 16, 2011
solids, primarily lignin, will be transferred to the steam/hot water heated dryer where the water
content will be reduced to approximately 50% moisture. The dried lignin will be stored in a silo
and either burned in the on-site boiler or sold as a product.
Frontier is proposing to generate electricity, steam, and hot water at the facility using a
535 MMBtu/hr bubbling fluidized bed boiler that will burn bark from the debarking process, lignin
from the lignin dryer, methane from the methanator, and biomass from the methanator. The
boiler will also use natural gas for start up. Sand, limestone, and ash associated with the boiler
will be stored in silos. Ash will be loaded into trucks and transported off-site.
Frontier is also proposing to use dry cooling at the facility. Therefore, there will be no air
emissions from cooling towers.
Frontier is proposing to have a 1,500 HP natural gas fired emergency generator and a 500 HP
natural gas fired emergency firewater pump.
The facility will be located in Chippewa County which is considered an attainment area for all
criteria pollutants.
Key Permit Review Issues
Staff evaluated the proposed project to identify all state rules and federal regulations which are,
or may be, applicable. The tables in Appendix 1 summarize these rules and regulations.

Prevention of Significant Deterioration (PSD) Regulations – The PSD major source
threshold is 250 tons per year for each of the criteria pollutants unless the source is one of
28 source categories listed in the PSD regulations, then the PSD major source threshold is
100 tons per year. Frontier is not one of the 28 listed source categories and the criteria
pollutant emission limits in the proposed permit are less than 250 tons per year. Therefore
Frontier is a minor source and is not subject to PSD review. Table A summarizes the
applicability of the PSD regulations to the criteria pollutants emitted from the proposed
facility.

Federal NSPS Regulations – New Source Performance Standards (NSPS) were
established under Title 40 of the Code of Federal Regulations (40 CFR) Part 60. The
proposed denaturant storage tank and denatured ethanol storage tanks are subject to the
NSPS for Volatile Organic Liquid Storage Vessels, 40 CFR Part 60, Subpart Kb. The
proposed boiler is subject to the NSPS for Industrial-Commercial-Institutional Steam
Generating Units, 40 CFR Part 60, Subpart Db, which applies to boilers with heat inputs of
more than 100 MMBtu/hr. The proposed natural gas fired emergency engines are subject to
the NSPS for Stationary Spark Ignition Internal Combustion Engines, 40 CFR Part 40
Subpart JJJJ. The proposed facility is also subject to the NSPS for Volatile Organic
Compound (VOC) emissions from leaks in equipment handling organic chemicals in 40 CFR
Part 60, Subpart VVa for.

Federal NESHAP Regulations - National Emission Standards for Hazardous Air Pollutants
(NESHAP) were established under Section 112 of the Clean Air Act and are found at
40 CFR Part 61 or Part 63. NESHAPS can apply to major sources, area sources, or both.
On February 21, 2011 EPA pre-published 40 CFR 63.7480, “National emission standards
for hazardous air pollutants for new and existing industrial/commercial/institutional boilers
and process heaters,” (Boiler MACT). Frontier is a new source under the Boiler MACT
Frontier Kinross, LLC
Permit No. 166-09A
Page 3
May 16, 2011
(40 CFR Part 63 Subpart JJJJJJ) and the boiler will be subject to those standards upon
startup.
EPA has also published the NESHAP for Stationary Reciprocating Internal Combustion
Engines, 40 CFR Part 63 Subpart ZZZZ (RICE MACT). The proposed natural gas fired
emergency engines will be subject to the RICE MACT.

Rule 224 TBACT Analysis – Rule 224 applies to new, or modified, emission units that emit
a Toxic Air Contaminant (TAC) and which do not have a corresponding emission standard
promulgated under Section 112 of the Clean Air Act or which emit TACs that are VOCs and
are in compliance with Best Available Control Technology (BACT) requirements.
TBACT does not apply to Frontier’s proposed boiler because Frontier is subject to the Boiler
MACT. TBACT also does not apply to Frontier’s proposed emergency engines because
Frontier is subject to the RICE MACT
Each emission unit emitting VOCs is expected to be in compliance with Rule 702 BACT
requirements. TBACT does not apply to emission units emitting VOCs.

Rule 225 Toxics Analysis – Michigan’s Rules for Air Pollution Control require the ambient
air concentration of TACs be compared against health-based screening levels. AQD staff
reviewed Frontier’s air quality modeling and evaluation of TAC impacts. The review found
that all TACs are either exempt from, or will comply with, the requirements of Rule 225.
Rule 226(a) exempts TACs that have low emission rates and are neither carcinogens nor
high concern TACs from the Rule 225 health-based screening level requirement. Table B
lists those TACs that are “exempt” from Rule 225.
Rule 227(1)(a) provides a simple method for demonstrating compliance with Rule 225 based
on the TAC’s emission rate and health based screening level(s). Table C summarizes the
results of the Rule 227(1)(a) Allowable Emission Rate analysis.
For those TACs not meeting the Rule 226(a) exemption or the Rule 227(1)(a) Allowable
Emission Rates, computer dispersion modeling was used to demonstrate compliance with
Rule 225. Table D summarizes the results of the dispersion modeling analysis.
In addition to the TACs in Tables B, C, and D, Frontier proposes to emit several TACs that
do not have established screening levels. For each of these TACs, the AQD Toxics Unit
evaluated the available toxicological information and the ambient impact from dispersion
modeling and determined that the predicted ambient impacts will comply with Rule 225.
Table E lists these TACs and their ambient impacts.

Rule 702 VOC Emissions – This rule requires an evaluation of the following four items to
determine what will result in the lowest maximum allowable emission rate of volatile organic
compounds (VOC):
a. BACT or a limit listed by the department on its own initiative
b. New Source Performance Standards (NSPS)
c. VOC emission rate specified in another permit
d. VOC emission rate specified in the Part 6 rules for existing sources
Frontier Kinross, LLC
Permit No. 166-09A
Page 4
May 16, 2011
The Rule 702 evaluation determined that the following control and operational requirements
meet Rule 702(a) for the associated equipment:







Wet scrubber with sodium bilsulfite injection for the wood chip pretreatment, the yeast
propagation tank, the fermentation tanks, the ethanol distillation and purification system,
the centrifuges, and the evaporator train.
Wet scrubber with sodium bilsulfite injection and an operating temperature of 185°F or
less for the lignin dryer.
A flare for loading tanker trucks and rail cars with ethanol.
Only railcars dedicated to transporting ethanol can be loaded at the facility.
Internal floating roofs for the ethanol storage tanks.
Good combustion practices and a VOC emission limit of 0.010 lb/MMBTU for the boiler.
Frontier must develop and implement a malfunction abatement plan.
The Rule 702 evaluation determined that compliance with NSPS Kb, including installing
internal floating roofs, meets Rule 702(b) for the denaturant and denatured ethanol storage
tanks.

Criteria Pollutants Modeling Analysis - Computer dispersion modeling was performed to
predict the impacts of the criteria pollutant emissions. The emissions from the proposed
facility were evaluated for compliance with the applicable National Ambient Air Quality
Standards (NAAQS) and the applicable PSD increments. The NAAQS are intended to
protect public health. The PSD increments are intended to allow industrial growth in an
area, while ensuring that the area will continue to meet the NAAQS.
The analysis demonstrated that the potential emissions will not exceed the NAAQS or PSD
increments. Tables F, G, and H summarize the results of the criteria pollutant modeling.
Key Aspects of Draft Permit Conditions

Emission Limits – The draft permit conditions include a variety of emission limits. Criteria
pollutants are limited to ensure the PSD increments and NAAQS will be met and that the
facility will be a minor source under the PSD regulations. Acrolein emissions are limited to
ensure compliance with Rule 225.
Hazardous air pollutant emissions, including
acetaldehyde and acrolein, are limited to ensure that the facility will be an “area source” of
hazardous air pollutants (HAPs).

Usage Limits – The natural gas heat input to the boiler is limited to 245 MMBtu/hr so that
the boiler is not a PSD major source. The draft permit also limits the facility wide natural gas
usage, the amount of lignin that can be produced, the ethanol and denaturant throughput,
and the wood throughput. These limits are needed to make various emission limits
enforceable.

Process/Operational Restrictions – The draft permit limits several operational parameters
of the proposed facility, including:
 Requiring the lignin dryer to operate at 185°F or less and limiting the moisture content of
the lignin produced to not less than 30%.
 Wood chips cannot be pneumatically conveyed to the wood chip silos.
 The denaturant storage tank (Tank 6) must be equipped with a submerged fill pipe.
Frontier Kinross, LLC
Permit No. 166-09A





Page 5
May 16, 2011
Only railcars that are dedicated to transporting ethanol, including denatured ethanol, can
be loaded at the facility.
The only fuels that can be burned in the boiler are natural gas, biogas, and biomass
which is defined as bark, lignin, and biomass from the methanator.
The emergency engines are limited to 100 operating hours each per year for
maintenance and a total of 500 operating hours per engine per year for any reason.
The draft permit requires Frontier to develop and implement a malfunction abatement
plan, an odor management plant, a fugitive dust control plan, and a plan that describes
how emissions will be minimized during all startups, shutdowns and malfunctions of the
boiler.
Federal Regulations –The proposed facility is subject to several New Source Performance
Standard (NSPS).
The NSPS for Volatile Organic Liquid Storage Vessels, at
40 CFR Part 60 Subpart Kb, will be met by equipping the denaturant storage tank and the
denatured ethanol storage tanks with internal floating roofs. The NSPS for IndustrialCommercial-Institutional Steam Generating Units, at 40 CFR Part 60 Subpart Db, will be met
by limiting the annual capacity factor of natural gas to 10% for the boiler, equipping the
boiler with a continuous opacity monitoring system or bag leak detection system, and
limiting the PM emission rate to 0.030 lb/MMBTU. The NSPS for Stationary Spark Ignition
Internal Combustion Engines, at 40 CFR Part 40 Subpart JJJJ, will be met by meeting the
VOC, CO, and NOx emission limits for the engines. The NSPS for VOC emissions from
leaks in equipment handling organic chemicals, at 40 CFR Part 60 Subpart VVa, will be met
by implementing leak detection and repair.
The proposed boiler is subject to the National Emission Standards for Hazardous Air
Pollutants (NESHAP) for Industrial, Commercial, and Institutional Boilers Area Sources,
40 CFR Part 63 Subpart JJJJJJ. Frontier will comply with the standard by limiting the visible
emissions and PM emissions from the boiler. The proposed natural gas fired emergency
engines are subject to the NESHAP for Stationary Reciprocating Internal Combustion
Engines, 40 CFR Part 63 Subpart ZZZZ. Frontier will comply with the standard by
complying with NSPS JJJJ.

Emission Control Device Requirements – The draft permit includes several emission
control device requirements to reduce the emissions from the facility:







A wet scrubber with sodium bisulfite injection is required to reduce VOC, HAP, and TAC
emissions from the wood chip pretreatment, the yeast propagation tank, the fermentation
tanks, the ethanol distillation and purification system, the centrifuges, the evaporator
train, and the lignin dryer.
Internal floating roofs are required to reduce VOC and TAC emissions from the ethanol,
denaturant, and denatured ethanol storage tanks.
A flare is required to reduce VOC and TAC emissions from loading tanker trucks and rail
cars with ethanol.
Fabric filters are required to reduce particulate emissions from wood chipping, the bark
hog, wood chip receiving, the sand silo, the limestone silo, the ash silo, and ash loadout.
Lignin storage and loadout are required to be conducted inside enclosures to reduce
particulate emissions.
A selective non-catalytic reduction (SNCR) system is required to reduce nitrogen oxides
(NOx) emissions from the boiler.
A fabric filter is required to reduce particulate emissions from the boiler.
Frontier Kinross, LLC
Permit No. 166-09A


Page 6
May 16, 2011
The fabric filter also reduces emissions of acid gases from the boiler, such as sulfur
dioxide and hydrogen chloride, by capturing alkaline wood ash that helps to neutralize
acid gas emissions.
Combustion controls will be used on the boiler to minimize carbon monoxide (CO), VOC,
and organic TAC and HAP emissions.

Testing Requirements – The draft permit includes several emission testing requirements,
including:
 VOC and acetaldehyde emissions from the equipment controlled by the wet scrubber.
 Acetaldehyde and acrolein emissions from the bark hog and wood chipping.
 PM, PM10, PM2.5, SO2, and VOC emissions from the boiler within 180 days of startup
and every five years thereafter.
 CO emissions from the boiler unless a CO continuous emission monitor is installed.
Repeat testing may be required depending on the initial test results.
 Acetaldehyde, acrolein, benzene, chlorine, formaldehyde, hydrogen chloride, methanol,
methyl isobutyl ketone, n-hexane, and styrene emissions from the boiler. Repeat testing
may be required depending on the initial test results.

Monitoring Requirements – The draft permit includes several monitoring requirements,
including:
 The wet scrubber water and sodium bisulfite flow rates.
 The lignin dryer operating temperature.
 The pressure drop of each fabric filter.
 Monthly visible emissions checks of the bark hog and wood chipping vent, wood chip
receiving, each of the storage silos, ash loadout, and lignin loadout.
 Continuous Emission Rate Monitoring System (CERMS) for NOx and oxygen or carbon
dioxide from the boiler.
 CERMS for CO from the boiler, unless Frontier elects to conduct stack testing for the CO
emissions from the boiler.
 Install a continuous opacity monitoring system (COMS) or a bag leak detection system
on the boiler.
Conclusion
Based on the analyses conducted to date, staff concludes that the proposed project would
comply with all applicable state and federal air quality requirements. Staff also concludes that
this project, as proposed, would not violate the federal National Ambient Air Quality Standards
or the state and federal PSD increments.
Based on these conclusions, staff has developed draft permit terms and conditions which would
ensure that the proposed facility design and operation are enforceable and that sufficient
monitoring, recordkeeping, and reporting would be performed by the applicant to determine
compliance with these terms and conditions. If the permit application is deemed approvable,
the delegated decision maker may determine a need for additional or revised conditions to
address issues raised during the public participation process.
If you would like additional information about this proposal, please contact Mr. Andrew Drury,
AQD, at 517-335-3107.
Frontier Kinross, LLC
Permit No. 166-09A
Table A - Applicability of PSD Regulations to Criteria Pollutants
PSD Major
PSD
Total Facility
Source
Subject
Significant
Pollutant
Emissions
Threshold
to PSD?
Emission
(tpy)
(tpy)
Rate (tpy
Particulate Matter (PM)
90 tpy
250
No
25
PM less than or equal to 10
151.9
250
No
15
microns diameter (PM10)
PM less than or equal 2.5
151.5
250
No
10
microns diameter (PM2.5)
Sulfur Dioxide (SO2)
53.4
250
No
40
Carbon Monoxide (CO)
234
250
No
100
Oxides of Nitrogen (NO2)
218.6
250
No
40
Volatile Organic
83.2
250
No
40
Compounds (VOC)
Lead**
0.048
0.6
No
0.6
* There are no PSD increments or NAAQS for PM or VOC
** Lead was evaluated as part of the toxic air contaminant review
Page 7
May 16, 2011
Subject to
Modeling?
N/A*
Yes
Yes
Yes
Yes
Yes
N/A*
No
Table B - Toxic Air Contaminants Meeting the Rule 226(a) Exemption From Rule 225
Toxic Air Contaminant
CAS
Toxic Air Contaminant
CAS
1,1-dichloroethane
75-34-3
cymene-p
99-87-6
1,2,3-trimethylbenzene
526-73-8
Cyclopentane
287-92-3
1,2,4-trimethylbenzene
95-63-6
di-n-butyl phthalate
84-74-2
1,1,1-trichloroethane
71-55-6
Diethylphthalate
84-66-2
1,2 dichloropropane (propylene dichloride)
78-87-5
dimethyl sulfide
75-18-3
1,3,5-trimethylbenzene
108-67-8
Fluoranthene
206-44-0
2-chlorophenol
95-57-8
Hexanal
66-25-1
2-methylnaphthalene
91-57-6
Isobutyraldehyde
78-84-2
2,2,4-trimethylpentane
540-84-1
methyl ethyl ketone
78-93-3
2,4-dinitrophenol
51-28-5
Methylcyclohexane
108-87-2
2,5-dimethyl benzaldehyde
5779-94-2
Molybdenum
7439-98-7
Acenaphthene
83-32-9
4-nitrophenol
100-02-7
Acenaphthylene
208-96-8
Nonane
111-84-2
Acetone
67-64-1
Octane
111-65-9
Acetophenone
98-86-2
Phenanthrene
85-01-8
alpha-pinene
80-56-8
Phosphorus
7723-14-0
Anthracene
120-12-7
Propionaldehyde
123-38-6
Biphenyl
92-52-4
Pyrene
129-0-0
bis(2-chloroisopropyl) ether
108-60-1
Silver
7440-22-4
butylbenzylphthalate
85-68-7
p-tolualdehyde
104-87-0
Butyraldehyde
123-72-8
Toluene
108-88-3
carbon disulfide
75-15-0
trichlorofluoromethane
75-69-4
Chlorobenzene
108-90-7
Valeraldehyde
110-62-3
Chloroethane
75-00-3
Vanadium
7440-62-2
Copper
7440-50-8
Xylene
1330-20-7
Frontier Kinross, LLC
Permit No. 166-09A
Page 8
May 16, 2011
Table C - Toxic Air Contaminant Allowable Emission Rates From Rule 227(1)(a)
Allowable
Frontier
Percent of
Averaging
TAC
Emission Rate
Emission Rate
Allowable
Time
(lb/ Avg. Time)
(lb/ Avg. Time) Emission Rate (%)
1 hour
0.0108
0.00068
6.3
1,1,2,2-tetrachloroethane
Month
0.8
0.51
63
1 hour
0.0324
0.00051
1.6
1,1,2-trichloroethane
Month
2.4
0.38
16
1 hour
0.108
0.000422
<1
1,3-dichloropropene
24 hour
2.4
0.01
4
Month
8
0.31
4
1 hour
0.1
0.00805
8
Barium
8 hour
0.1
0.0644
64
1 hour
0.162
0.000476
<1
Benzaldehyde
Month
16
0.354
2.2
1 hour
22.4
0.881
4
Beta-pinene
8 hour
22.4
7.1
31
1 hour
0.108
2.64 x 10-5
<1
Bis(2-ethylhexyl)phthalate
Month
8
0.02
<1
1 hour
0.486
0.00813
1.7
Bromomethane
Month
36
6
17
1 hour
476
0.523
<1
n-Butane
8 hour
476
4
<1
1 hour
0.216
0.00101
<1
Carbazole
Month
16
0.751
4.7
1 hour
0.216
0.00828
3.8
Chloroform
Month
16
6.16
39
1 hour
0.1
0.00857
8.6
Chromium (III)
8 hour
0.1
0.07
69
1 hour
0.004
0.000299
7.5
Cobalt
8 hour
0.004
0.0024
60
1 hour
0.0756
0.000294
<1
Dichlorobenzene
24 hour
36
0.00706
<1
Month
5.6
0.219
3.9
1 hour
380
14.9
3.9
Ethanol
8 hour
380
119
31
1 hour
1.62
0.0178
1
Ethylbenzene
24 hour
120
0.427
<1
Month
120
13.24
11
1 hour
7
0.193
2.8
Fluorene
24 hour
16.8
4.63
28
1 hour
35
0.7621.03
2.2
Hexane
24 hour
84
18
22
1 hour
2.1
0.59
28
Hydrogen Chloride
Month
800
442
55
1 hour
0.25
0.0084
3.4
Methyl Bromide
24 hour
0.6
0.02
34
Frontier Kinross, LLC
Permit No. 166-09A
TAC
Methyl Chloride
Methyl Isobutyl Ketone
Methanol
Methylene Chloride
Pentane
Pentachlorophenol
Perchloroethylene
Phenol
Selenium
Tin
Trichloroethylene
2,4,6-trichlorophenol
Total PAH*
Page 9
May 16, 2011
Averaging
Time
1 hour
24 hour
Month
1 hour
24-hour
1 hour
1 hour
Month
1 hour
8 hour
1 hour
24 hour
Month
1 hour
Month
1 hour
1 hour
8 hour
1 hour
8 hour
1 hour
Month
1 hour
Month
1 hour
Month
Allowable
Emission Rate
(lb/ Avg. Time)
0.864
10.8
64
150
360
3.25
1.08
80
354
354
0.00486
2.4
0.36
0.918
68
0.6
0.04
0.04
0.4
0.4
0.324
24
0.162
12
0.00027
0.02
Frontier
Emission Rate
(lb/ Avg. Time)
0.00644
0.15
4.79
0.238
5.71
1.69
0.0816
60.7
0.679
5
1.43 x 10-5
0.000343
0.011
0.0107
7.96
0.16
8.58 x 10-5
0.00069
0.000258
0.00206
0.00842
6.26
6.14 x 10-6
0.00457
6.48 x 10-6
0.00482
Percent of
Allowable
Emission Rate (%)
<1
1.4
7.5
<1
1.6
52
7.6
76
<1
1.5
<1
<1
3
1.2
12
27
<1
1.7
<1
<1
2.6
26
<1
<1
2.4
24
* Total polycyclic aromatic hydrocarbon (PAH) weighted as Benzo(a)pyrene, including the following
compounds: Benz(a)anthracene, Benzo(a)pyrene, Benzo(b)fluoranthene, Benzo(k)fluoranthene, Chrysene,
Dibenzo(a,h)anthracene, Indeno(1,2,3cd)pyrene
Frontier Kinross, LLC
Permit No. 166-09A
Page 10
May 16, 2011
Table D - Toxic Air Contaminant Impacts From Dispersion Modeling
Frontier
Percent of
Averaging
ITSL
IRSL
SRSL
TAC
Impact
Screening
Time
(µg/m3)
(µg/m3)
(µg/m3)
(µg/m3)
Level (%)
1,3-butadiene
24-hr
2
0.26
13%
1,3-butadiene
Annua;
0.03
0.0052
17%
Acetaldehyde
24-hr
9
1.3
15
Acetaldehyde
Annual
0.5
0.086
17
Acrolein
1-hr
5
2.3
45
Acrolein
Annual
0.02
0.0185
93
Ammonia
24-hr
100
0.3
<1
Antimony
24-hr
0.2
0.0006
<1
Arsenic
Annual
0.0002
0.000013
6.7
Benzene
24-hr
30
0.41
1.4
Benzene
Annual
0.1
0.017
17
-6
Beryllium
24-hr
0.02
2.7 x 10
<1
Beryllium
Annual
0.0004
2.45 x 10-7
<1
Cadmium
Annual
0.0006
4.24 x 10-6
<1
Carbon Tetrachloride
Annual
0.17
0.0073
4.3
Chlorine
24-hr
0.3
0.017
5.8
Chromium (VI)
24-hr
0.1
0.0016
<1
Chromium (VI)
Annual
0.000083
0.0000026
3.1
Cumene
Annual
0.1
6.97 x 10-5
<1
2,4-dinitrotoluene
Annual
0.009
3.59 x 10-6
<1
Ethylene Dichloride
Annual
0.04
6.06 x 10-5
<1
Formaldehyde
Annual
0.08
0.043
53
Gasoline
Annual
20
6.22
31
Hexachlorobenzene
Annual
0.002
3.93 x 10-6
<1
Isopropanol
24-hr
220
0.15
<1
-4
Lead*
24-hr
1.5
8.64 x 10
<1
Manganese
Annual
0.0042
0.00018
<1
Mercury**
24-hr
0.3
5.17 x 10-5
<1
Naphthalene
24-hr
3
0.074
2.5
Naphthalene
Annual
0.08
0.015
18
Nickel
Annual
0.0042
0.0003
7
Styrene
24-hr
1000
0.08
<1
Styrene
Annual
1.7
0.007
<1
Thallium
24-hr
0.2
0.0001
<1
Total Dioxin/Furans and
Annual
2.3 x 10-8
7.5 x 10-9
33
Dioxin like PCBs as
2,3,7,8-TCDD
Total PCBs
Annual
0.002
9.11 x 10-8
<1
Vinyl Chloride
24-hr
100
0.015
<1
Vinyl Chloride
Annual
0.11
0.003
2.7
* The lead impact on a 24 hour averaging time was compared to the quarterly NAAQs. Given the low
lead emission rate and low impact, further evaluation of the lead emissions in not warranted.
** The mercury impact was compared to the inhalation based screening level. Mercury emissions
from the source are also less than five pounds per year. Emissions at this rate are not expected to
present concerns calling for an enhanced review.
Frontier Kinross, LLC
Permit No. 166-09A
Page 11
May 16, 2011
Table E - Toxic Air Contaminants With Acceptable Impacts
Toxic Air Contaminant
CAS
Acceptable Impact (µg/m3)
1,2-dibromoethylene
540-49-8
6.53 x 10-4
2-chloronapthalene
91-58-7
2.67 x 10-8
4,6-dinitro-2-methylphenol
534-52-1
7.99 x 10-6
Alpha-terpineol
10482-56-1
5.24 x 10-5
Benzoic acid
65-85-0
4.43 x 10-4
Crotonaldehyde
123-73-9
1.15 x 10-4
Iron
15438-31-0
1.10 x 10-2
2-monochlorobiphenyl
2051-60-7
2.42 x 10-9
2-nitrophenol
88-75-5
3.00 x 10-6
Perylene
198-55-0
1.08 x 10-8
Potassium
7440-09-7
2.15 x 10-3
Sodium
7440-23-5
4.00 x 10-3
Strontium
7440-24-6
1.16 x 10-4
Titanium
7440-32-6
4.64 x 10-6
o-Tolualdehyde
529-20-4
8.35 x 10-5
Yttrium
7440-65-5
3.48 x 10-6
Zinc
7440-66-6
1.30 x 10-4
Pollutant
PM2.5
PM2.5
PM10
PM10
SO2
SO2
SO2
SO2
NO2
NO2
CO
CO
Pollutant
PM10
PM10
NO2
Table F - Preliminary Modeling Impacts
PSD Significant Predicted Impact
Averaging Time
Level (µg/m3)
(µg/m3)
24-hr
1.2
14.27
Annual
0.3
0.73
24-hr
5
30.1
Annual
1
2.18
1-hour
7.9
4.39
3-hr
25
3.67
24-hr
5
1.23
Annual
1
0.13
1-hr
5
126.38
Annual
1
2.25
1-hr
2,000
252.74
8-hr
500
137.54
Additional
Modeling?
Yes
Yes
Yes
Yes
No
No
No
No
Yes
Yes
No
No
Table G - PSD Increment Analysis
PSD Increment
Predicted Impact
Averaging Time
(µg/m3)
(µg/m3)
Annual
17
2.18
24-hr
30
19.44
Annual
25
1.69
Percent of
Increment (%)
12.81
64.8
6.74
Frontier Kinross, LLC
Permit No. 166-09A
Page 12
May 16, 2011
Table H - National Ambient Air Quality Standards (NAAQS) Analysis
Predicted Impact
NAAQS
Percent of
Pollutant
Averaging Time
plus
Background
3
(µg/m )
NAAQS (%)
(µg/m3)
PM10
Annual
50
19.18
38
PM10
24-hr
150
50.42
34
PM2.5
Annual
15
8.06
54
PM2.5
24-hr
35
33.24
95
NO2
Annual
100
11.99
12
NO2
1-hr
188
167.61
89
Frontier Kinross, LLC
Permit No. 166-09A
Page 13
May 16, 2011
Appendix 1
STATE AIR REGULATIONS
State Rule
R 336.1201
R 336.1205
R 336.1224
R 336.1225 to
R 336.1232
R 336.1279 to
R 336.1290
R 336.1299(2)(b)
R 336.1301
R 336.1331
R 336.1370
R 336.1401 and
R 336.1402
R 336.1601 to
R 336.1651
R 336.1702
R 336.1801
R 336.1901
Description of State Air Regulations
Requires an Air Use Permit for new or modified equipment that emits, or could emit, an air
pollutant or contaminant. However, there are other rules that allow smaller emission
sources to be installed without a permit (see Rules 336.1279 through 336.1290 below).
Rule 336.1201 also states that the Department can add conditions to a permit to assure the
air laws are met.
Outlines the permit conditions that are required by the federal Prevention of Significant
Deterioration (PSD) Regulations and/or Section 112 of the Clean Air Act. Also, the same
types of conditions are added to their permit when a plant is limiting their air emissions to
legally avoid these federal requirements. (See the Federal Regulations table for more
details on PSD.)
New or modified equipment that emits toxic air contaminants must use the Best Available
Control Technology for Toxics (T-BACT). The T-BACT review determines what control
technology must be applied to the equipment. A T-BACT review considers energy needs,
environmental and economic impacts, and other costs. T-BACT may include a change in
the raw materials used, the design of the process, or add-on air pollution control equipment.
This rule also includes a list of instances where other regulations apply and T-BACT is not
required.
The ambient air concentration of each toxic air contaminant emitted from the project must
not exceed health-based screening levels. Initial Risk Screening Levels (IRSL) apply to
cancer-causing effects of air contaminants and Initial Threshold Screening Levels (ITSL)
apply to non-cancer effects of air contaminants. These screening levels, designed to protect
public health and the environment, are developed by Air Quality Division toxicologists
following methods in the rules and U.S. EPA risk assessment guidance.
These rules list equipment to processes that have very low emissions and do not need to
get an Air Use permit. However, these sources must meet all requirements identified in the
specific rule and other rules that apply.
Adopts by reference the provisions of 40 CFR 63.40 to 63.44 (2002) and 40 CFR 63.50 to
63.56 (2002), the federal hazardous air pollutant regulations governing constructed or
reconstructed major sources.
Limits how air emissions are allowed to look at the end of a stack. The color and intensity of
the color of the emissions is called opacity.
The particulate emission limits for certain sources are listed. These limits apply to both new
and existing equipment.
Material collected by air pollution control equipment, such as dust, must be disposed of in a
manner, which does not cause more air emissions.
Limit the sulfur dioxide emissions from power plants and other fuel burning equipment.
Volatile organic compounds (VOCs) are a group of chemicals found in such things as paint
solvents, degreasing materials, and gasoline. VOCs contribute to the formation of smog.
The rules set VOC limits or work practice standards for existing equipment. The limits are
based upon Reasonably Available Control Technology (RACT). RACT is required for all
equipment listed in Rules 336.1601 through 336.1651.
New equipment that emits VOCs is required to install the Best Available Control Technology
(BACT). The technology is reviewed on a case-by-case basis. The VOC limits and/or work
practice standards set for a particular piece of new equipment cannot be less restrictive than
the Reasonably Available Control Technology limits for existing equipment outlined in Rules
336.1601 through 336.1651.
Nitrogen oxide emission limits for larger boilers and stationary internal combustion engines
are listed.
Prohibits the emission of an air contaminant in quantities that cause injurious effects to
human health and welfare, or prevent the comfortable enjoyment of life and property. As an
example, a violation may be cited if excessive amounts of odor emissions were found to be
preventing residents from enjoying outdoor activities.
Frontier Kinross, LLC
Permit No. 166-09A
Page 14
May 16, 2011
STATE AIR REGULATIONS
State Rule
R 336.1910
R 336.1911
R 336.1912
R 336.2001 to
R 336.2060
R 336.2501 to
R 336.2514
R 336.2801 to
R 336.2804
Prevention of
Significant
Deterioration
(PSD)
Regulations
Best Available
Control
Technology
(BACT)
R 336.2901 to
R 336.2903 and
R 336.2908
Description of State Air Regulations
Air pollution control equipment must be installed, maintained, and operated properly.
When requested by the Department, a facility must develop and submit a malfunction
abatement plan (MAP). This plan is to prevent, detect, and correct malfunctions and
equipment failures.
A facility is required to notify the Department if a condition arises which causes emissions
that exceed the allowable emission rate in a rule and/or permit.
Allow the Department to request that a facility test its emissions and to approve the protocol
used for these tests.
Regulates mercury emissions from any stationary coal-fired electric generating unit (EGU)
serving a generator with a nameplate capacity of more than 25 megawatts producing
electricity for sale. The program begins January 1, 2015 and contains provisions for existing
and new EGUs. Mercury program eligibility provisions and prohibitions, demonstration
plans, testing, monitoring, record keeping, and reporting are all part of the rule.
The PSD rules allow the installation and operation of large, new sources and the
modification of existing large sources in areas that are meeting the National Ambient Air
Quality Standards (NAAQS). The regulations define what is considered a large or significant
source, or modification.
In order to assure that the area will continue to meet the NAAQS, the permit applicant must
demonstrate that it is installing the BACT. By law, BACT must consider the economic,
environmental, and energy impacts of each installation on a case-by-case basis. As a
result, BACT can be different for similar facilities.
In its permit application, the applicant identifies all air pollution control options available, the
feasibility of these options, the effectiveness of each option, and why the option proposed
represents BACT. As part of its evaluation, the Air Quality Division verifies the applicant’s
determination and reviews BACT determinations made for similar facilities in Michigan and
throughout the nation.
Applies to new “major stationary sources” and “major modifications” as defined in R
336.2901. These rules contain the permitting requirements for sources located in
nonattainment areas that have the potential to emit large amounts of air pollutants. To help
the area meet the NAAQS, the applicant must install equipment that achieves the Lowest
Achievable Emission Rate (LAER). LAER is the lowest emission rate required by a federal
rule, state rule, or by a previously issued construction permit. The applicant must also
provide emission offsets, which means the applicant must remove more pollutants from the
air than the proposed equipment will emit. This can be done by reducing emissions at other
existing facilities.
As part of its evaluation, the AQD verifies that no other similar equipment throughout the
nation is required to meet a lower emission rate and verifies that proposed emission offsets
are permanent and enforceable.
FEDERAL AIR REGULATIONS
Citation
Section 109 of the
Clean Air Act –
National Ambient
Air Quality
Standards
(NAAQS)
Description of Federal Air Regulations or Requirements
The United States Environmental Protection Agency has set maximum permissible levels
for seven pollutants. These NAAQS are designed to protect the public health of
everyone, including the most susceptible individuals, children, the elderly, and those with
chronic respiratory ailments. The seven pollutants, called the criteria pollutants, are
carbon monoxide, lead, nitrogen dioxide, ozone, particulate matter less than 10 microns
(PM10), particulate matter less than 2.5 microns (PM2.5), and sulfur dioxide. Portions of
Michigan are currently non-attainment for either ozone or PM2.5. Further, in Michigan,
State Rules 336.1225 to 336.1232 are used to ensure the public health is protected from
other compounds.
Frontier Kinross, LLC
Permit No. 166-09A
Page 15
May 16, 2011
FEDERAL AIR REGULATIONS
Citation
40 CFR 51
Appendix S
Emission Offset
Interpretive Ruling
40 CFR 52.21 –
Prevention of
Significant
Deterioration
(PSD) Regulations
Best Available
Control
Technology
(BACT)
40 CFR 60 –
New Source
Performance
Standards (NSPS)
40 CFR 63 –
National
Emissions
Standards for
Hazardous Air
Pollutants
(NESHAP)
Description of Federal Air Regulations or Requirements
Appendix S applies during the interim period between nonattainment designation and
EPA approval of a SIP that satisfies nonattainment requirements specified in Part D of
the Clean Air Act. Appendix S would apply in nonattainment areas where either no
nonattainment permit rules apply or where the existing state rules are less stringent than
Appendix S.
The PSD regulations allow the installation and operation of large, new sources and the
modification of existing large sources in areas that are meeting the NAAQS. The
regulations define what is considered a large or significant source, or modification.
In order to assure that the area will continue to meet the NAAQS, the permit applicant
must demonstrate that it is installing BACT. By law, BACT must consider the economic,
environmental, and energy impacts of each installation on a case-by-case basis. As a
result, BACT can be different for similar facilities.
In its permit application, the applicant identifies all air pollution control options available,
the feasibility of these options, the effectiveness of each option, and why the option
proposed represents BACT. As part of its evaluation, the Air Quality Division verifies the
applicant’s determination and reviews BACT determinations made for similar facilities in
Michigan and throughout the nation.
The United States Environmental Protection Agency has set national standards for
specific sources of pollutants. These New Source Performance Standards (NSPS) apply
to new or modified equipment in a particular industrial category. These NSPS set
emission limits or work practice standards for over 60 categories of sources.
The United States Environmental Protection Agency has set national standards for
specific sources of pollutants. The National Emissions Standards for Hazardous Air
Pollutants (NESHAP) (a.k.a. Maximum Achievable Control Technology (MACT)
standards) apply to equipment in a particular industrial category. These NESHAPs set
emission limits or work practice standards for over 100 categories of sources.
Section 112 of the
Clean Air Act
In the Clean Air Act, Congress listed 189 compounds as Hazardous Air Pollutants
(HAPS). For facilities which emit, or could emit, HAPS above a certain level, one of the
following two requirements must be met:
Maximum
Achievable Control
Technology
(MACT)
1) The United States Environmental Protection Agency has established standards for
specific types of sources. These Maximum Achievable Control Technology
(MACT) standards are based upon the best-demonstrated control technology or
practices found in similar sources.
Section 112g
2) For sources where a MACT standard has not been established, the level of control
technology required is determined on a case-by-case basis.
Notes: An “Air Use Permit,” sometimes called a “Permit to Install,” provides permission to emit air contaminants
up to certain specified levels. These levels are set by state and federal law, and are set to protect health and
welfare. By staying within the levels set by the permit, a facility is operating lawfully, and public health and air
quality are protected.
The Air Quality Division does not have the authority to regulate noise, local zoning, property values, offsite truck traffic, or lighting.
These tables list the most frequently applied state and federal regulations. Not all regulations listed may be
applicable in each case. Please refer to the draft permit conditions provided to determine which regulations
apply.