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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

174) II-F-1 

Docket Number: 

A-90-06 

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State of WiHeonsin \ DEPARTMEN i ur INA I UMAU RESOURCES 

February 5, 1988 

Mr. Joseph Paisie, Chief 

PFCEIVED 

<F9 0 9 1988 

Carroll 0. Bissd/i) 

Saontso 

00X7921 

MADISON, WISCONSIN 53707 

IN REPLY REFER TO: 4530 

Technical Analysis Section ^LI^ITA^'V * 

Air and Radiation Branch (5AR2BTmr"TM*mn 

U.S. Environmental Protection Agency 

230 South Dearborn Street 

Chicago, IL 60604 

i' 11 

. ->^jrn-r- rmTf >SWii.i i 

4 

1 

33 

Dear Mr. Paisie: 

Pursuant to item 8 of the U.S. EPA - WDNR PS0 delegation agreement of November 

13, 1987, our agency seeks concurrence on our Interpretation of section 40 CFR 

52.21 as It relates to the proposed renovations at Wisconsin Electric Power 

Company (WEPCO) - Port Washington. The issue at hand 1s the applicability of 

PSD review to this utility boiler life extension project. 

Don Theiler's letter of November 9, 1987 to Steve Rothblatt presented our view 

of Wisconsin law governing major source modifications. The Wisconsin 

Department of Natural Resources has determined that neither the proposed 

renovations of the units at the Port Washington power plant nor the resumption 

of operation of Unit 5 are subject to new source review under the Wisconsin 

SIP. The November 9 letter also Indicated that the repairs to Unit 5 will, 

amount to only 3-5X of the fixed capital cost of a comparable (but brand-new) 

boiler system. Similarly, the proposed renovations for each of Units 1-4 will 

require an expenditure of far less than 50% of the replacement cost of a new 

boiler. Therefore, the renovations for each unit will not constitute 

"reconstruction", so that the provisions of New Source Performance Standards 

(NSPS) will not apply. 

Routine maintenance, repair and replacement do not constitute major 

modifications to a source. (40 CFR 52.2l(b)(2)(MJXa)). The Department's 

Investigation Into the WEPCO-Port Washington situation has concentrated on the 

nature of the renovations proposed for the five units (boilers). Because of 

our limited expertise in utility boiler maintenance, we have consulted 

Wisconsin Public Service Commission (PSC) engineering staff for assistance In 

evaluating the planned maintenance activities. Allen Hubbard of our new 

source review staff has also discussed the life extension project at the 

Beckjord Power Station near Cincinnati with Tom Tucker of the Southwestern 

Ohio Air Pollution Control Agency (S0APCA). 

Utility boiler life extension projects, such as the WEPCO-Port Washington 

plant restoration, are of keen Interest to PSC. A letter summarizing PSC's 

thoughts on the Port Washington project and how 1t fits 1n with Wisconsin's 

utility Advance Plans 1s In process. SOAPCA's Mr. Tucker Indicated that the 
Mr. Joe Paisie, Chief - February 4, 1988 2. 

Beckjord renovations, which like those proposed for Port Washington simply 

restored boiler capacity which had been lost due to the normal aging of 

utility boilers, were determined to be exempt from PSD because they 

represented Increases 1n the production rates of sources which are limited In 

capacity by a SIP. Such Increases are specifically exempted from PSD review 

by 40 CFR 52.2l(b)(2)(111)(f). 

It 1s the opinion of DNR that the renovations at WEPCO-Port Washington are 

similar to those at Beckjord and are Indeed routine 1n nature for a utility. 

Therefore, like at Beckjord, a PSD permit Is not required of WEPCO for 

undertaking the proposed plant Hfe extension activities. 

What Is your view of our interpretation of the applicability of the PSD 

regulations to the WEPCO-Port Washington renovations? We believe that you 

,~J"fin agree that WEPCO may proceed with this life extension project without a 

'^>S D permit. (If EPA1 staff need further 1nform*t+©n^to^svarruate tfctt.*-**W-«5K%LK. 

situation, we would appreciate It If they would tell us what Information Is 

needed. Too often in the past people have Just said "more Information Is 

needed" without specifying the exact nature of that missing Information.) 

Sincerely, 

Dale Ziege, P.*E. 

Source Review Unit 

Engineering & Surveillance Section 

Bureau of Air Management 

DZ:AH:Jmc/2725E 

cc: Donald Theiler - AM/3 

Allen Hubbard - AM/3 

Dan Johnston - AM/3 

Tom Steldl - LC/5 

Marcla Penner - LC/5 

Wolf Klassen - SED 

Jeff Berger - SED 

Jim Leverance - Wisconsin Public Service Commission 

Steve Brick - Wisconsin Public Service Commission 

Dan Dasho - Wisconsin Public Service Commission 

Mark Steinberg - WEPCO \ 

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