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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

229) 11-1-9 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:51:02 AM Sheet 229 of 276 
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State of Wisconsin \ DEPARTMENT OF 

August 7, 1989 

Mr. Mark P. Steinberg 

Superintendent - Air Quality 

Environmental Department 

Wisconsin Electric Power Company! 

P.O. Box 2046 

Milwaukee, Wl 53201 

Dear Mr. Steinberg: 

Sscntaiy 

BOX 7921 

MADISON. WISCONSIN 53707 

File Ref.: 4530 

AU6 H 1989 

J -UL m 

PORT WASHINGTON POWER PLANT RENOVATION PROJECT 

PSD PERMIT BACT ANALYSIS: RESPONSE TO WEPCO'S MAY 30, 1989 SUBMITTAL 

The Department understands from your letter to Donald Theiler of May 30, 1989 

that although WEPCO is not requesting that DNR proceed with formulating a PSD 

permit for the above-referenced renovation project, Wisconsin Electric Power 

Company (WEPCO) does wish to ascertain DNR's and EPA's judgements concerning 

the current status of N0X BACT as it would apply to a PSD project at the Port 

Washington Power Plant. 

The May 30, 1989 submittal, with its extensive documentation from a variety of 

sources, is indeed impressive. In fact, the Department's Allen Hubbard and 

Steve Frey of Wisconsin Power & Light are carefully reviewing these documents 

as part of their efforts to develop realistic NO control recommendations in 

the context of Wisconsin Act 296 and its mandated nitrogen oxides emission 

reduction cost study. 

While the selective non-catalytic reduction (SNCR) techniques evaluated in 

your BACT analysis, urea injection and ammonia Injection, are promising 

technologies for N0X control, we agree with your conclusion that SNCR Is not 

yet ready for commercial application to pulverized coal, arch-fired utility 

boilers such as the units at Port Washington. It appears that the existing 

firing configurations make application of SNCR problematic for these 

particular sources, if for no other reason than excessive retrofit costs. 

On the other hand, the Department has recently become aware of significant 

advances In selective catalytic reduction (SCR) for N0X control. Several 

documents of interest are attached to this letter. One is a copy of a recent 

decision from William K. Reilly, the new Administrator of EPA. This decision 

from EPA headquarters has been widely distributed within EPA, so that 1t 

arrived at DNR via EPA's Regional Office 1n Chicago. Mr. Reilly remanded a 

PSD permit to the State of Kentucky in part because Kentucky did not require 

N0X controls 1n the "normal" expenditure range of $3000-6500. 
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Mr. Mark P. Steinberg - page 3. 

evaluate the potential of this technology as BACT for the renovated Port 

Washington arch-fired boilers. 

If you have any questions about this response to your May 30 submittal, please 

do not hesitate to call Allen Hubbard of my section at (608) 266-3450. We are 

eager to assist you through the permitting process for the Port Washington 

renovations. 

Sincerely, 

Dale L. Ziege, Chief 

Permits Section 

Bureau of Air Management 

pji 

cc: Joe Paisie - EPA Region V 

Tom Steldl - LC/5 

Marcia Penner - LC/5 

Don Theiler - AM/3 

Allen Hubbard - AM/3 

Dan Schramm - SED 

Dan Dasho - PSC