BY BENJAMIN J. GOHS, EDITOR
An upcoming public hearing will focus on a settlement between the Michigan Department of Environmental Quality (MDEQ) and Kirtland Products as well as the wood pellet manufacturer’s plan to address future emissions concerns.
Kirtland Products of Boyne City faces a $5,000 fine for allegedly violating air pollution standards; but, air quality officials are confident a plan to more than double the limit of particulate matter output will bring the company into compliance without endangering the public.
Subscribers have access to all accompanying official documents related to this story.
“MDEQ alleges that the company (Kirtland) exceeded the Particulate Matter (PM) emission limit from the EUBAGHOUSE and exceeded the PM emission limit from FGGRINDER/DRYER, as cited herein and in a violation notice dated Oct. 29, 2015,” it states in an MDEQ Air Quality Division (AQD) draft consent order.
According to MDEQ, though an increase in emission limits is being requested, the requested amounts are well under what the law allows.
“Kirtland Products has proposed a new emission limit for the plant-wide baghouse exhaust stack that is 6 percent of the emission limit allowed by law,” MDEQ states.
“They have proposed a new emission limit for the grinder/dryer exhaust stack that is 27.4 percent of the emission limit allowed by law for the dryer.”
While, MDEQ states, tests conducted on April 21, 2015, show both EUBAGHOUSE and FGGRINDER/DRYER exceeded emission limits for particulate matter, “[C]ompliance testing for particulate matter equal to or less than 10 microns in diameter (PM10) and particulate matter equal to or less than 2.5 microns in diameter (PM2.5) conducted on the same date was not approved by the AQD; therefore, the results were not found to be acceptable. Both the draft Consent Order and draft PTI No. 47-11E require that the PM10 and PM2.5 testing be performed again.”
Current Air Quality
According to MDEQ, Kirtland is currently meeting all National Ambient Air Quality Standards (NAAQS), which cover PM10, PM2.5, ozone, carbon monoxide, sulfur dioxide, nitrogen dioxide and lead.
“Particulate (small particles of dust) is the primary pollutant of concern for this facility,” MDEQ states. “While the AQD does not operate a particulate air monitoring station in Charlevoix County, we do operate one in Missaukee County near Houghton Lake. The Littler River Band of Ottawa Indians also operates a particulate monitoring station in Manistee County near Manistee. Both of these stations show that the air quality in the area currently meets the PM2.5 health based NAAQS.”
Further, particulate matter is, according to MDEQ, the only regulated air pollutant for which Kirtland Products is requesting an increase in allowed emissions.
“The potential to emit from the facility for PM was about 34 tons per year (tpy), and with the proposed increases, it will go to about 76 tpy,” MDEQ states.
Emission Test Factors
According to MDEQ, the manufacture of wood pellets for fuel is a relatively new industry. This severely limits data on emissions tests.
“Testing has shown that the moisture content of the green wood used to begin the process can affect emissions,” MDEQ states.
“The moisture content of the wood greatly affects the temperature required in the dryer and how long the drying takes. Higher moisture contents require hotter and longer drying times.”
It further states, “The moisture content also affects the volume of the exhaust gases. Each of these factors can affect emissions.”
MDEQ documents show Kirtland Products’ first emissions tests on particulate matter in September 2012, using dry green wood, which MDEQ says was not representative of Kirtland’s normal operation.
“When they tested again in April of 2015, they used green wood with a higher moisture content, which is more representative of their normal operation. This higher moisture content is believed to be one of the reasons why Kirtland Products failed their April 2015 stack testing,” MDEQ states….
“Another item which may have added to the failed stack test is how Kirtland Products both operated and maintained their baghouse and two cyclones. In response to this, they had an independent engineering group evaluate EUBAGHOUSE. The engineering group made several suggestions to Kirtland Products concerning operational changes—such as how often the bags are cleaned—which should improve the effectiveness of EUBAGHOUSE.”
MDEQ says some of those suggestions have been incorporated into the Kirtland baghouse’s existing malfunction abatement plan.
Resolving the matter
Kirtland Products has a plan to address future emissions issues and MDEQ has what it calls “stipulated penalties” which are pre-agreed-upon amounts intended to prevent industrial operations from violating environmental regulations.
According to MDEQ, the initial fine could have been higher but, “A reduced penalty amount was accepted in this case because Kirtland Products provided sufficient financial documentation that indicated an inability to pay.”
However, MDEQ states, “As future non-compliance would be costly to Kirtland Products, the stipulated penalties provide an incentive to stay in compliance.”
The consent order shows a future fine amount of up to $3,000 per violation.
The public comment period—as was originally noticed in the Wednesday June 1 edition of the Boyne City Gazette—is scheduled from June 1 through July 11 for the facility located at 1 Altair Drive in Boyne City.
“It has been preliminarily determined that the increase in allowable PM emissions will not violate any of the MDEQ’s rules nor the National Ambient Air Quality Standards,” the MDEQ states in its notice.
The informational session and public hearing on the matter have been scheduled for 6 p.m. and 7 p.m. respectively on Monday July 11, at the Boyne District Library, 201 East Main St. in Boyne City.
Further information on the matter can be found in the following locations:
• Copies of the MDEQ’s analyses, proposed draft Consent Order, and proposed draft permit conditions are available for review at the following locations, or you may request a copy be mailed to you by calling 517-284-6793. Please reference PTI Application No. 47-11E for Kirtland Products.
• Air Quality Division (AQD) Internet Home Page – http://www.michigan.gov/air
• CADILLAC: MDEQ, AQD, 120 West Chapin Street, Cadillac, MI 49601-2158 (Phone: 231-876-4411)
• LANSING: MDEQ, AQD, Constitution Hall, 2nd Floor, South Tower, 525 West Allegan Street, Lansing, Michigan 48933-1502 (Phone: 517-284-6793)
• BOYNE CITY: City Hall, 319 North Lake St., Boyne City, Michigan 49712 (Phone: 231-582-6597)
You may comment during the public hearing. You may also submit your thoughts in writing.
For views on the Draft Consent Order, mail to:
Mr. Jason Wolf, Michigan Department of Environmental Quality, Air Quality Division,
P.O. Box 30260, Lansing, Michigan, 48909-7760.
Written comments for the PTI should be sent to:
Ms. Annette Switzer, Permit Section Supervisor, Michigan Department of Environmental Quality, Air Quality Division,
P.O. Box 30260, Lansing, Michigan, 48909-7760.
Comments related to the PTI may also be submitted on the web at
Click on “Submit Comment” under the Kirtland Products, PTI No. 47-11E listing. All statements received by July 11, 2016 will be considered by the decision-maker prior to final action on both the Consent Order and the PTI.