p.1 

OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

231)11-1-11 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:51:02 AM Sheet 231 of 276 
P.2 

Wisconsin 

Electric 

POWER COMPANY 

II-I-ll 

231 W. Michigan. PO. Box 2046. Milwaukee. Wl 53201 (414)221-2345 

March 29, 1990 

Mr. Dale Ziege 

Wisconsin Department of Natural Resources 

P. 0. Box 7921 

Madison, Wisconsin 53707 

Dear Mr. Ziege: 

On July 13, 1987, Wisconsin Electric submitted an application to 

the Public Service Commission of Wisconsin ("PSCW") for a 

certificate of authority to conduct certain renovation work at its 

Port Washington Power Plant. As you may recall, the PSCW requested 

the. Department of Natural Resources ("DNR" or "the Department") to 

determine what, if any, permits might be required for the work, and 

DNR in turn consulted the U.S. Environmental Protection Agency 

("EPA"). 

Although DNR, by letter dated February 5, 1988, determined that the 

proposed work would not constitute a modification for new source 

review purposes, EPA, exercising its oversight authority of DNR's 

decisions, disagreed and issued two decisions, October 14, 1988 and 

February 15, 1989, holding that the work, if done as proposed, 

would constitute a modification subjecting Units 1, 4 and 5 to New 

Source Performance Standard (NSPS) requirements, and the Port 

Washington Plant to Prevention of Significant Deterioration (PSD) 

requirements. The company challenged EPA's decisions and on 

January 19, 1990, the United States Court of Appeals for the 

Seventh Circuit rendered its decision vacating and remanding to 

EPA, the Agency's determination that the project, if conducted as 

proposed, would constitute a major modification subjecting the Port 

Washington Power Plant to the PSD program. 

The purpose of this letter is to formally request DNR's 

determinations: 1) That in accordance with the standard set forth 

in Wisconsin Electric v. Reillv [893 F.2d 901 (7th Cir. 1990)], 

there will be no significant net emissions increase as a result of 

the proposed work and thus, PSD is not applicable; 2) That the 

capacity and emission rate, as proposed by the company, for Units 1 

through 4, constitute the baseline for purposes of NSPS 

applicability and "net out;" 3) That an NSPS triggering 

modification will only occur for N0X on Units 1 and 4; and 4) That 

if Unit 5's baseline is zero, only it will be subject to NSPS for 

particulates, SO2 and N0X. 

A subsidiary of Wisconsin Energy Corporation 
P.3 

Mr. Dale Ziege 

March 29,.1990 

Page 2 

Copies of this letter are being sent to EPA Headquarters and 

Region V. While the company understands that DNR has been 

delegated PSD authority, the active involvement of both Region V 

and, to a greater extent, EPA Headquarters personnel, up to the 

level of Assistant Administrator for Air & Radiation, has, in the 

company's judgment, set Port Washington apart from the typical PSD 

permit case. Given the fact that the company's proposed schedule 

has been delayed by over two years as a result of EPA's initial 

action and the court challenge, the company does not believe that 

additional delay, which would be occasioned by working first with 

the Department, =then with Region V, and then possibly EPA 

Headquarters, all in series, would be warranted. The company hopes 

that it could work with both the state and federal regulatory 

agencies on the same time frame so that further delays to the 

project can be minimized. In this regard, the PSCW has recently 

initiated a proceeding to determine the generating capacity needed 

by the Wisconsin utilities in the 1994-96 time period. It is 

important to the company's participation in that proceeding that 

it know how much of its Port Washington capacity it can rely on. 

A DNR decision prior to May 1, 1990, would be appreciated. 

PSD Methodology 

The Court in Wisconsin Electric v. Reillv rejected and remanded 

EPA's determination that post project emissions for PSD 

modification purposes should be determined on the basis that the 

facility operates at 100 percent capacity factor. In its decision, 

the Court provided guidance concerning how emissions from sources 

that have an operating history should be calculated for purposes 

of determining whether or not there will be a significant net 

emissions increase. Actual post project emissions should be 

determined on the basis of the emissions that would result if the 

source were operated as it is intended to be operated and as it is 

normally operated. In footnote 14 of its decision (Wisconsin 

Electric v. Reillyr 893 F.2d 901, 918), the Court indicated that 

EPA's determination whether the Port Washington Plant will be 

subject to the PSD program would depend upon whether the renovated 

plant would cause a significant net emissions increase if it were 

operated under present hours and conditions. 

In determining whether proposed work at a source constitutes a 

modification for PSD purposes, Section 40 C.F.R. 52.21 requires a 

comparison of the source's actual annual emissions during a 

representative period prior to the contemplated work, with the 

source's actual emissions following completion of such work. 

Wisconsin Electric believes that the Court's decision regarding PSD 

is compatible with EPA's rules. As applied to Port Washington, the 
P.4 

Mr. Dale Ziege 

March 29, 1990 

Page 3 

company believes that the Court's decision requires a comparison 

of actual emissions during a representative period prior to the 

proposed renovation work with projected post-renovation emissions 

determined, assuming that Port Washington operated with the same 

capacity factor as it did during the representative pre-renovation 

period. 

In this case, since EPA has already decided that 1983 and 1984 

constitute the representative pre-renovation period for Port 

Washington (letter dated October 14, 1988, Lee M. Thomas to John W. 

Boston), the determination of whether or not the proposed 

renovation work at Port Washington would constitute a PSD 

modification should be relatively easy and straightforward. Port 

Washington's post-renovation actual emissions should be based upon 

the emissions that would result if the plant were operated during 

the post-renovation period as it operated during the representative 

period. If there would be no significant net increase in 

emissions, then the proposed renovation would not constitute a PSD 

modification. In determining whether there would be a net 

significant emissions increase, contemporaneous increases and 

decreases in emissions, as well as the significance levels set 

forth in 40 C.F.R. Section 52.21(b)(23) would, of course, apply. 

NSPS - Baseline Capacity and Emissions 

The applicability of NSPS to the various units at Port Washington 

and the amount of emission reductions required at each unit in 

order to "net out" of NSPS must be established in order to conduct 

the PSD calculations. These NSPS issues depend in turn on the prerenovation baseline capacity established for each unit and the 

related baseline emission rate. 

EPA's October 14, 1988 determination established baseline capacity 

and corresponding emission levels for Port Washington Units 1-5 

based on the maximum level at which the units were operated to meet 

electrical system requirements in 1987. Based on the results of 

testing done by the company in late 1988, EPA, on February 15, 

1989, revised upward the baselines of Units 2 and 3 such that the 

proposed work on these units should not result in a capacity 

increase and NSPS should not be triggered. The resulting unit 

baseline capacities, expressed in thousands of pounds of boiler 

feedwater per hour, are shown on Table 1, line 2 (attached). 

On October 5, 1989, EPA, under the authority of Section 114 of the 

Clean Air Act, requested the company to conduct particulate/opacity 

tests on Units l and 4. The company conducted the requested tests 

and determined that the units could reliably operate in an 
P.5 

Mr. Dale Ziege 

March 29, 1990 

Page 4 

economically sustainable fashion in compliance with applicable 

standards, at higher capacities than had been established by EPA 

as their baseline levels. Test reports were submitted to DNR and 

EPA. The company requests that the capacities as determined by the 

emission testing be considered as new baseline levels for Units 1 

and 4 for purposes of NSPS applicability and net out. These 

capacity levels are shown on Table 1, line 3. 

The company believes that the baseline particulate emission rates 

for Units 1-4 should be as determined during the fall 1988 capacity 

tests of Units 2 and 3, and during the fall 1989 tests of Units 1 

and 4. Table 2, line 3, shows the pre-renovation particulate 

emission rates in pounds per hour for Units 1-5 based on these 

particulate emission test results. 

The company believes that the results of particulate emission tests 

should be used in lieu of EPA's "10 A" emission factor (which had 

been used in calculating particulate emissions by EPA in its 

October 14, 1988 determination). The "10 A" factor is not 

appropriate or representative of Port Washington given the design 

of the plant, which is somewhat unique in the industry. 

The "10 A" particulate emission factor assumes an equal split of 

the ash stream between fly ash and bottom ash. In actuality, 

(based on company records) Port Washington's fly ash/bottom ash 

split is approximately 85/15, which is the split factor previously 

used in EPA's AP-42 document. Port Washington's fuel system stores 

pulverized coal in bunkers for subsequent injection into the boiler 

(bin and feeder) as contrasted with the general practice in the 

industry of injecting pulverized coal directly and immediately into 

the furnace. The ventage from the Port Washington pulverizers, 

which contains particulate matter, is routed to the precipitator, 

as contrasted with the practice on other units of routing the 

pulverizer discharge to the boiler. The "10 A" emission factor 

does not recognize pulverizer ventage as a component of 

precipitator inlet loading. 

The furnace flame configuration at the Port Washington units, which 

results in the extremely low N0X emission rates, also contributes 

larger amounts of unburned coal to the precipitators than would be 

the case with units having a more conventional furnace flame 

configuration. The "10 A" emission factor does not recognize the 

Unit 5, which was not tested, has a zero baseline. 
P.6 

Mr. Dale Ziege 

March 29, 1990 

Page 5 

Port Washington level of unburned coal inlet loadings to the 

precipitators. 

The above three items, fly ash/bottom ash split, pulverizer ventage 

and furnace unburned coal, result in artificially low baseline 

precipitator inlet loadings and corresponding low particulate 

emission rates if the "10 A" emission factor is used in the 

emission calculations. In addition, the emission factor method 

does not account for increased post renovation particulate loading 

which will be caused by use of dry sorbent injection (DSI) for SO2 

control on Units-1 and 4. Particulate emission tests will, by 

their very nature, account for all sources of particulate matter 

to the precipitators. Thus, the company believes that the results 

of the 1988 particulate emission tests on Units 2 and 3 and the 

1989 particulate emission tests on Units 1 and 4, be used to 

establish the baseline for these units. Post renovation 

particulate emissions would also be determined from emission tests 

and, if less than the . baseline values, would confirm that 

particulate NSPS would not be applicable. 

Baseline SO2 and NOx emission rates were calculated using the same 

unit capacities as for particulates. Coal having the same 

characteristics as used in 1987, upon which EPA's October 14, 1988 

determination was based, was assumed to be burned. 

NSPS and PSD Applicability 

Table 2 summarizes pre- and post renovation emissions for all five 

units. Baseline particulate emissions were calculated using the 

results of the fall, 1988, and fall, 1989 tests on Units 2-3 and 

Units 1-4, respectively. Pre-renovation NOxemissions for Units 2, 

3 and 4 are calculated based upon unit-specific NOx emission tests 

conducted in the early 1980's, the results of which were used by 

EPA in its October 14, 1988 determination. In reviewing various 

materials, the company became aware of the fact that the Unit 1, 

NOx baseline rates used by EPA was erroneously overstated. As a 

result of lack of specific test data showing a lower emission rate, 

EPA, in its October 14, 1988 determination, used the AP-42, NOx 

emission factor for coal-fired boilers resulting in an 

inappropriately large baseline NOx emission rate for Unit 1. 

Although the company realizes that the increase in baseline 

emission rate for Unit 1 NOx would be in its favor, the company 

does not believe that use of inappropriate emission factors is 

correct, regardless of whom they favor. The company thus has 

revised the Unit 1 NOxemission factor and recalculated Unit l's NOx 
PJL 

Mr. Dale Ziege 

March 29, 1990 

Page 6 

emission rate to a level it believes proper based upon the results 

of the tests on Units 2, 3 and 4. 

Controlled SO2 emissions under the post renovation portion of 

Table 2 are based upon dry sorbent injection on Units l and 4 to 

the extent necessary to result in no emission rate increase. 

Particulate emissions on Units 1 through 5 reflect precipitator 

improvements on all five units resulting in an anticipated emission 

rate of approximately 0.04 lbs. per million BTU. 

The results of Table 2 demonstrate that following the renovation 

project Units.1 through 4 will not exceed their pre-renovation 

emission rates for particulates and SO2, that Units 2 and 3 will 

not exceed the pre-renovation emission rate for N0X, but that 

Units 1 and 4 will exceed their pre-renovation emission rates for 

N0X. However, since the post renovation emission rates for NOx from 

Units 1 through 5 will, on a unit-specific basis, each meet the 

40 C.F.R. Part 60, Subpart D(a), NSPS requirement of 0.6 lbs. per 

million BTU, the only NSPS related impact will be the requirement 

on Units l, 4 and 5 to install continuous emission monitors and 

submit to reporting and recordkeeping. Unit 5 will have to meet 

full NSPS for SO2 and particulates. 

Tables 3 and 4 show the results of a PSD analysis conducted in 

accordance with the Court's decision in Wisconsin Electric v. 

Reilly. using the average of 1983 and 1984 operations and emissions 

as representative PSD baseline emissions. The post renovation 

actual projected emissions shown in Table 3 for particulates are 

based upon all five units equipped with 99.2 percent efficient 

precipitators, while the particulate matter post renovation 

emissions shown on Table 4 are based upon only Units 1-4 being in 

operation. As can be seen from Tables 3 and 4, the proposed 

renovation project will not cause the Port Washington Power Plant 

to become a modified source for PSD purposes. 

The above NSPS and PSD analyses demonstrate that except for Unit 5, 

the only pollutants for which there will be an increase subjecting 

certain portions of the plant to being considered as a modification 

are the NOx emission rates on Units 1 and 4. These increases would 

cause Units 1 and 4 to be subject to NSPS for N0X. However, since 

the units already emit at rates lower than NSPS, the company does 

not believe that the renovation project should subject it to any 

additional controls other than installation of monitors and 

reporting/recordkeeping. 

Consistent with the Court's decision regarding Port Washington and 

with the distinction raised by the First Circuit in Puerto Rican 
P.8 

Mr. Dale Ziege 

March 29, 1990 

Page 7 

Cement Co. v. EPA (889 F.2d 292, 1st Cir. 1989), the company does 

not believe its post-renovation operation would be restricted to 

the pre-renovation operation used for the before/after emissions 

test. To the extent that a comparison of pre-renovation actual 

representative emissions with actual post-renovation emissions 

consistent with the Seventh Circuit's decision indicates that there 

will not be a significant net increase in emissions, the company 

believes that its future operations at Port Washington should be 

governed, for modification purposes, by the provisions of 

Section 40 C.F.R. 52.21(b)(2). Thus, an increase in the hours of 

operation or production rate of the Port Washington Plant in the 

future to respond to market conditions consistent with EPA's rules, 

would not result in a finding that the source had been modified. 

Response to EPA Data Reguest 

At its March 16, 1990 meeting with the company, EPA staff requested 

that information be provided showing actual projected post 

renovation emissions from the plant on an annual basis reflecting 

one percent increases in annual plant capacity factors. Tables 5 

and 6 provide the requested information. Table 5 (two pages) shows 

one percent increases in capacity factors from 20 through 80 

percent, assuming all five units are in operation. Table 6 (two 

pages) provides a similar capacity factor/emission analysis, but 

assumes that only Units 1 through 4 at Port Washington are in 

operation in the post renovated time frame. Table 6 assumes that 

Unit 5's post renovation emissions are zero. 

Table 7 responds to EPA staff's request for public information 

concerning the company's projected operations of Port Washington 

in the future and the high side error band around those annual 

operating forecasts. It should be understood that by their nature, 

forecasts get less certain as they go further into the future, both 

in terms of operation and emission rates. Although unit emission 

rates have been assumed to remain constant in the future, these 

rates may change. 

Conclusion 

We will meet with you on the morning of Friday, March 30, to 

discuss the above information. As you know, the company is anxious 

to move this matter along, especially in view of the Public Service 

Commission of Wisconsin's recently instituted 1994-96 generation 

capacity proceeding. The company will need to know the extent to 

which it can count on generation from Port Washington to be in 

service during the 1994-1996 time frame. In this regard, planned 
P.9 

Mr. Dale Ziege 

March 29, 1990 

Page 8 

unit outages at Port Washington to conduct the necessary renovation 

work will render certain of the units inoperable for six to nine 

month periods, thus affecting the company's future capacity plans. 

During the March 16, 1990 meeting with the company, EPA senior 

staff mentioned that Wisconsin Electric's acceptance of a PSD 

permit might result in a more speedy resolution of the issues, than 

would attempting to demonstrate that PSD does not apply. Although 

the company believes that the proposed project should not result 

in a PSD modification of the plant, it would like to move forward 

with its proposed .repair project. Accordingly, the company would 

be willing to explore the possibility of a PSD permit based on 

current NSPS-NOx rates being considered BACT and use of appropriate 

emissions calculation methods and net out periods. 

Very truly yours, 

Walter T. Woelfle 

Counsel 

pb 

Enclosures 

cc: Donald F. Theiler - WDNR, Bureau of Air Management 

William G. Rosenberg - EPA Assistant Admin, of Air & Radiation 

Lydia Wegman - EPA Chief of Staff, Air & Radiation 

^Jtffin Calcagni - EPA, Research Triangle Park 

David Kee - Director - EPA Region V, Air & Radiation Division 

Barbara James - Public Service Commission of Wisconsin 

Michael Jaeger - Public Service Commission of Wisconsin 

Lanny Smith - Public Service Commission of Wisconsin 

Henry V. Nickel - Hunton & Williams 

Anthony s. Earl - Quarles & Brady 
TABLE 1 

PORT WASHINGTON POWER PLANT 

FULL LOAD CAPACITY m 

P.10 

October 14, 1988 

EPA determination. 

i 

458 

2. 

610 

Unit 

2 

666 

4. 

447 

5 

0 

2. October 14, 1988 EPA 

determination as modified 

by February 15, 1989, 

determination. 

3. October 14, 1988 EPA 

determination as modified 

by February 15, 198.9, 

determination and Wisconsin 

Electric Fall 1989 tests. 

4. Expected post-renovation 

capacity. 

458 

524 

690 

694 

694 

694 

690 

690 

690 

447 

580 

655 640 

(1) Operating capacity is expressed as unit feedwater flow, in Klb/hr. 
P.11 

TABLE 2 

PORT WASHINGTON POWER PLANT 

RENOVATION PROJECT - NSPS APPLICABILITY 

Full Load Emissions at Current, Representative Pre-renovation Baseline Capacity 

Parameter 

Operating Level (feedwater flow 

in Klb/hr) (1) 

S02 Emissions (lb/hr) (2) 

PM Emissions (lb/hr) (1) 

NOx Emissions (lb/hr) (2) 

I 

524 

1619 

62 

314 

2 

694 

2057 

105 

396 

Unit 

2 

690 

2122 

81 

300 

1 

580 

1870 

40 

261 

5 

0 

0 

0 

0 

Projected Full Load Emissions at Future (Design) Capacity 

(Post-renovation) 

Parameter 

Operating Level (feedwater flow 

in Klb/hr) 

Uncontrolled S02 Emissions 

(lb/hr) (3) 

Controlled S02 Emissions 

(lb/hr) (4) 

PM Emissions (lb/hr) (5) 

With Additional Control 

NOx Emissions (lb/hr) (6) 

I 

690 

2058 

1605 

40 

399 

2 

694 

2057 

2057 

32 

396 

Unit 

2 

690 

2122 

2122 

32 

300 

1 I 

655 640 

2125 2004 

1849 500 

37 25 

(NSPS) 

296 350 

Emissions 

Parameter 

S02 

PM -

NOx 

- Controlled 

Added Control 

NSPS Applicability 

I 

No (7) 

No 

Yes (8) 

2 

NO 

NO 

NO 

Unit 

2 

NO 

No 

No 

1 

No (7) 

No 

Yes (8) 

5 

Yes 

Yes 

Yes (8) 

Notes: 

(1) 

(2) 

tf) 

(4) 

(5) 

(6) 

(7) 

(8) 

Operating data and particulate emissions from 1988 and 1989 testing. 

S02 and NOx emissions based on 1988 and 1989 operating levels and 1987 coal quality. 

Uncontrolled S02 emissions based on expected operating levels and 1987 fuel quality. 

Controlled S02 emissions based on assumptions from Footnote 3, with 22X, 13%, and 75% S02 removal on Units 1, 4, and 

5, respectively. 

Particulate Matter (PM) emissions based on expected ESP inlet loadings, 99.2X ESP performance and 1987 fuel quality. 

- Unit 5 is NSPS. 

NOx emissions based on expected operating levels, current full load NOx emission rates, and 1987 fuel quality. 

S02 emissions on Units 1 and 4 will net out of NSPS requirements by partial S02 removal. 

Existing NOx emission rates already less than NSPS. Requires CEMS for NOx. 
PORT WASHINGTON POWER PLANT 

UNITS 1-5 

RENOVATION PROJECT - PSD APPLICABILITY 

(ALL EMISSIONS ARE IN TONS PER YEAR) 

TABLE 3 

March 28, 1990 

POLLUTANT 

Particulate Matter 

Sulfur Dioxide 

Nitrogen Oxides 

PRE-RENOVATION (1) 

ACTUAL EMISSIONS 

BASELINE 

328 (2) 

24,236 

2,592 (3) 

POST-RENOVATION (4) 

ACTUAL PROaJECTED 

EMISSIONS 

224 (5) 

10,458 

2,435 

NET-EMISSION 

INCREASE 

No 

No 

No 

PSD 

LEVEL 

25 

40 

40 

SUBJECT 

TO PSD 

REVIEW 

No 

No 

No 

NOTES: 

1. Average actual emissions for two year representative period 1983 a ^ 1984. 

2. Particulate Matter (PM) emissions based on 1983-1984 actual operating levels, coal 

characteristics, precipitator efficiencies, 85V15* fly ash-bottom ash split, and 

measured loss on ignition (LOl) values in fly ash. 

3. NOx emissions adjusted downward to reflect Unit l's representative NOx emission 

rate. 

4. Actual projected emissions based on 1983 and 1984 operating hours and levels, and 

post-renovation emission rates for FM and S02 to satisfy NSPS net-out requirements. 

Current and future NOx emissions (Ib/MBtu) are less than NSPS requirement. 

5. Precipitator removal efficiency on Units 1-4 is 99.2%; Unit 5 is NSPS. 

TJ 

to 
PORT WASHINGTON POWER PLANT 

UNITS 1-4 

RENOVATION PROJECT - PSD APPLICABILITY 

(ALL EMISSIONS ARE IN TONS PER YEAR) 

NOTES: 

1. Average actual emissions for two year representative period 1983 and 1984. 

2. Particulate Matter (PM) emissions based on 1983-1984 actual operating levels, coal 

characteristics, precipitator efficiencies, 85%/15% fly ash-bottom ash split, and 

measured loss on ignition (LOl) values in fly ash. 

3. NQx emissions adjusted dowra^rd to reflect Unit l's representative NQx emission 

rate. 

4. Actual projected emissions based on 1983 and 1984 operating hours and levels, and 

post-renovation emission rates for PM and S02 to satisfy NSPS net-out requirements. 

Current and future NOx emissions (lb/MBtu) are less than NSPS requirement. 

5. Precipitator removal efficiency on Units 1-4 is 99.2%. 

TABLE 4 

March 28, 1990 

POLLUTANT 

Particulate Matter 

Sulfur Dioxide 

Nitrogen Oxides 

PRE-RENOVATION (1) 

ACTUAL EMISSIONS 

BASELINE 

328 (2) 

24,236 

2,592 (3) 

POST-RENOVATION (4) 

ACTUAL PROJECTED 

EMISSIONS 

238 (5) 

12,794 

2,398 

NET-EMISSION' 

INCREASE 

No 

No 

No 

PSD 

LEVEL 

25 

40 

40 

SUBJECT 

TO PSD 

REVIEW 

No 

No 

No 

TJ 
PORT WASHINGTON POUER PLANT 

PROJECTED AMMJAL EMISSION 

UNITS 1-5. 1987 COAl. 

TABLE 5 

Page 1 of 2 

03/29/90 

Capacity 

Factor. V. 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

Heat Input 

(MBtu/yr) x 10to 

B.l 

8.5 

8.9 

9.3 

9.7 

10.1 

10.5 

10.9 

11.4 

11.8 

12.2 

12.6 

13.0 

13.4 

13.8 

14.2 

14.6 

15.0 

15.4 

15.8 

16.2 

16.6 

17.0 

17.4 

17.8 

18.2 

18.6 

19.1 

19.5 

19.9 

20.3 

Projected • 

Coal Consumption 

Tons/yr 

306,460 

321,783 

337,106 

352,429 

367,752 

383,075 

398,398 

413,721 

429,044 

444,367 

459,690 

475,013 

490,336 

505,659 

520,982 

536,305 

551,628 

566,951 

582,274 

597,597 

612,920 

628,243 

643,566 

658,BB9 

674,212 

689,535 

704.858 

720.181 

735,504 

750,827 

766,150 

Annua 1 

S02 Emiss ions 

Tons/yr 

7,581 

7,960 

8,339 

8,718 

9,097 

9,476 

9,855 

10.234 

10,613 

10,992 

11,371 

11,750 

12,129 

12,508 

12,867 

13,266 

13,645 

14,024 

14,403 

14.7B2 

15,161 

15,540 

15,919 

16,299 

16,678 

17,057 

, 17,436 

17,815 

18,194 

18,573 

18,952 

Annua 1 

Particulate Emissions 

Tons/yr 

154 

162 

169 

177 

185 

193 

200 

208 

216 

223 

231 

239 

246 

254 

262 

270 

277 

285 

293 

3D0 

3D8 

316 

323 

331 

339 

347* 

354 

362 

370 

377 

385 

Annua 1 

NOx Emissions 

Tons/kT 

1,622 

1,703 

1,784 

1,865 

1,946 

2,027 

2,108 

2,189 

2,270 

2,351 

2,432 

2,513 

2,594* 

2.676 

2,757 

2,838 

2.919 

3,000 

3,081 

3,162 

3.243 

3,324 

3,405 

3.486 

3,567 

3,648 

3,730 

3,811 

3,892 

3,973 

4.054 

Plant 502 Emission Rate = 1.87 Ib/MBtu 

Plant PM Emission Rate = 0.038 Ib/MBtu 

Plant NOx Emission Rate = 0.4D Ib/MBtu 

H Approximate level ot baseline 

emissions plus PS0 

s igni t icant level. 

Maximum Allowable Emmissions 

Without Triggering PSD' 

PM - 353 

S02 - 24,276 

NOx - 2.632 
PORT WASHINGTON POWER PLANT 

PROJECTED ANNUAL EMISSION 

UNITS 1-5. 19B7 COAL 

TABLE 5 

Page 2 of 2 

D3/2V/90 

Capacity 

Factor. % 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

61 

62 

63 

64 

65 

66 

67 

68 

69 

70 

71 

72 

73 

74 

75 

76 

77 

78 

79 

80 

Heat Input 

(MBtu/yr) x iab 

20.7 

21.1 

21.5 

21.9 

22.3 

22.7 

23.1 

23.5 

23.9 

24.3 

24.7 

25.1 

25.5 

25.9 

26.4 

26.8 

27.2 

27.6 

28.0 

2B.4 

28.8 

29.2 

29.6 

30.0 

30.4 

30.8 

31.2 

31.6 

32.0 

32.4 

Projected 

Coal Consumption 

Tons/yr 

781,473 

796,796 

812,119 

827,442 

842,765 

858,088 

873,411 

888,734 

904,057 

919,380 

934,703 

950,026 

965,349 

980,672 

995,995 

1,011,318 

1,026,641 

1,041,964 

1,057,287 

1,072,610 

1,087,933 

1,103,256 

1,118,579 

1,133,902 

1,149,225 

1,164,548 

1,179,871 

1,195,194 

1,210,517 

1,225,840 

Annua 1 

S02 Emiss ions 

Tons/yr 

19,331 

19,710 

20,089 

20,468 

20,847 

21,226 

21,605 

21,984 

22,363 

22,742 

23,121 

23,500 

23,879 

24,258* 

24,637 

25,D16 

25,395 

25,774 

26,153 

26,532 

26,912 

27,291 

27,670 

2B,049 

28,428 

28,807 

29,186 

29,565 

29,944 

30.323 

Annua 1 

Particulate Emissions 

Tons/yr 

393 

4D1 

408 

416 

424 

431 

439 

447 

454 

462 

470 

478 

485 

493 

501 

508 

516 

524 

531 

539 

547 

555 

562 

570 

578 

585 

593 

601 

608 

616 

Annua 1 

NOx Emission 

Tons/vr 

f 

4.135 

4,216 

4,297 

4,378 

4,459 

4.54D 

4,621 

4,702 

4,784 

4,865 

4,94*6 

5,027 

5,108 

5,189 

5,270 

5,351 

5,432 

5,513 

5,594 

5,675 

5,756 

5,838 

5,919 

6,000 

6,081 

6,162 

6,243 

6,324 

6,405 

6,486 

Units 1 S. 4 1989 Baseline Capacity 

Units 2 8. 3 1988 Baseline Capacity 

Unit 5 NSPS 

tt Approximate level ot baseline 

emissions plus PSD 

signi ticant level. 

Particulates -

Expected Precipitator PertormanceUnit 

1 

2 

3 

4 

5 

•n 

99.2 

99.2 

99.2 

99.2 

NSPS 

Ib/Mbtu 

0.045 

0.036, 

0.036 

0.042 

0.03D 
TABLE 6 

Page 1 of 2 

PORT WASHINGTON POWER PLANT 

PROJECTED ANNUAL EMISSION 

LIMITS 1-4, 1987 COAL 03/29/90 

Capac i ty 

Factor, V. 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

' 46 

47 

48 

49 

50 

Heat Input 

(fBtu/yr) x IO1 

6.5 

6.8 

7.1 

7.5 

7.8 

B.l 

8.4 

8.8 

9.1 

9.4 

9.7 

10.1 

10.4 

10.7 

11.0 

11.4 

11.7 

12.0 

12.3 

12.7 

13.0 

13.3 

13.6 

13.9 

14.3 

14.6 

14.9 

15.2 

15.6 

15.9 

16.2 

Prajacttd 

Coal Consumption 

Tons/yr 

245,240 

257,5D2 

269,764 

282,026 

294,288 

306,550 

318,812 

331,D74 

343,336 

355,598 

367,860 

380,122 

392,384 

404,646 

416,908 

429,170 

441,432 

453,694 

465,956 

478,218 

490,480 

502,742 

515,004 

527,266 

539,528 

551,790 

564,052 

576,314 

588,576 

600,838 

613,100 

Annua 1 

S02 Emissions 

Tons/yr 

7,072 

7,426 

7,779 

8,133 

B,486 

8,840 

9,194 

9,547 

9,901 

10,254 

10,608 

10,962 

11,315 

11,669 

12,022 

12,376 

12,730 

13,083 

13,437 

13,790 

14,144 

14,498 

14,851 

15,205 

15,558 

15,912 

16,266 

16,619 

16,973 

17,326 

17,680 

Annua 1 

Particulate Emissions 

Tons/yr 

130 

136 

143 

149 

156 

162 

169 

175 

182 

IBS 

195 

201 

208 

214 

221 

227 

234 

240 

247 

253 

260 

266 

272 

279 

285 

292 

298 

3D5 

311 

318 

324 

Annua 1 

NOx Emissions 

Tons/yr 

1,298 

1,362 

1,427 

1,492 

1,557 

1,622 

1,687 

1,752 

1,817 

1,882 

1,946 

2,011 

2,076 

2,141 

2,206 

2,271 

2,336 

2,401 

2,465 

2,530 

2,595* 

2,660 

2,725 

2,790 

2,855 

2,920 

2,985 

3,049 

3,114 

3,179 

3,244 

Plant 502 Emission Rate =2.18 Ib/MBtu 

Plant PM Emission Rate-= 0.040 Ib/MBtu 

Plant NOx Emission Rate = 0.4D Ib/MBtu 

tt Approximate level ot baseline 

emissions plus PSD 

s igni t icant level. 

Maximum Allowable Emmissi ons 

Without Triggering PSD" 

PM - 353 

S02 - 24,276 

NOx - 2,632 
PORT WASHINGTON POWER PLANT 

PROJECTED ANNUAL EMISSION 

UNITS 1-4, 1987 COAL 

TABLE 6 

Page 2 of 2 

03/29/90 

Capac ity 

Factor, 7. 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

61 

62 

63 

64 

65 

66 

67 

. 68 

69 

7D 

71 

72 

73 

74 

75 

76 

77 

78 

79 

60 

Heat Input 

(MBtu/yr) x 10b 

16.5 

16.9 

17.2 

17.5 

17.8 

18.2 

18.5 

18.B 

19.1 

19.5 

19.8 

20.1 

20.4 

2D.8 

21.1 

21.4 

21.7 

22.1 

22.4 

22.7 

23.0 

23.4 

23.7 

24. D 

24.3 

24.7 

25.0 

25.3 

25.6 

26.0 

Projected 

Coal Consumption 

Tons/yr 

625,362 

637,624 

649,886 

662,148 

674,410 

686,672 

698,934 

711,196 

723,458 

735,720 

747,982 

760,244 

772,506 

784,768 

797,030 

8D9,292 

821,554 

833,816 

846,078 

858,34D 

870,602 

882,864 

895,126 

907,388 

919,650 

931,912 

944,174 

956,436 

968,698 

980,960 

Annua 1 

S02 Emiss ions 

Tons/yr 

18,034 

18.3B7 

18,741 

19,094 

19,448 

19,802 

20,155 

20,509 

20,862 

21,216 

. 21,570 

21,923 

22,277 

22,630 

22,984 

23,338 

23,691 

24,045* 

24,398 

24,752 

25,106 

25,459 

25,813 

26,166 

26,520 

26,874 

27,227 

27,581 

27,934 

28,288 

Annua 1 

Particulate Emissions 

Tons/yr 

331 

337 

344 

35D* 

357 

363 

370 

376 

383 

389 

396 

4D2 

409 

415 

422 

428 

435 

441 

448 

454 

461 

467 

474 

480 

487 

493 

500 

506 

513 

519 

Annua 1 

NOx Emi ss i ons 

Tons/yr 

3,309 

3,374 

3,439 

3.504 

3.568 

3,633 

3,698 

3,763 

3.828 

3,893 

3,958 

4,023 

4,087 

4,152 

4,217 

4,282 

4,347 

4,412 

4,477 

4,542 

4,607 

4,671 

4,736 

4,801 

4,866 

4,931 

4,996 

5,061 

5,126 

5,190 

Units 1 8. 4 1989 Baseline Capacity 

Units 2 8. 3 1988 Baseline Capacity 

Particulates -

Expected Precipitator Pertormance: 

tt Approximate level ot base Ii ne 

emissions plus PSD 

s igni t icant level. 

Unit 

1 

2 

3 

4 

- **n 

99.2 

99.2 

99.2 

99.2 

Ib/Mbtu 

0.045 

0.036 

G.036 

0.042 
P.18 

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32DD B D TONS 

O -r-t LU 1 U — Z 1 Q: I J -J 3 1 ui < m i 3 O 1 U. U 1 >- 1 

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NSUMPTI ON 32DD Btu/lb ) D TONS 

O ^ U 1 U — Z 1 

or. i 

_J -1 3 1 

UJ <t m i 

3 O 1 

l i. U 1 >- i i - or i -« O 1 U l - 1 < U 1 Q. <t 1 < u. i 

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f- Ul 1 

i- cn i- t 

< QC < 1 3 3 CK 1 

<OU) 1 

LD X Z 1 Ul Ul 1 — LD 1 YEAR 

a3NstcD-oo--ir^n-at-ati>no- a 

-a*ncvjvO-it--oNT-<Lnr-aarHroain 

mro>0(Di/)Ln-J3>it*^«--ii>in-r-i(>i

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-(j*aaOco 

•-: H M>-4 to a-* CM CM IN ro -4 -a ro 

ro-at«*««tLnin-o-aO»ONO-aO>o>o>o-o -4 r- --i CM -o co • CM CM ro ro ro ro -* 

tM^-ta^-I^HCMCMlMtM 

-"f--ta*-at-t-at-at- * 

• oaaociciaooonoo D 

ODa-iNro-ooiN-taNCMT-t-atrOarH 

•Dr-Dr-HO-CMCOa-0CMCM--Hr

v

*CMtMCO 

Nr*-DroNroco-at-^r-,-at--tT-.-atff-

LO Tl ar-l CM -tf CO CO O D 

•* 

a-H 

r-l 

r-

<t 

f> a^-t -TH 

a N T - ( 

• CO -r-l 

ro 

•ttj>coNroro-oco<D-i i 

CM ro ro -4 -t

f - t •tf 

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m-oi^coo^DT-aCMro-tinaaOP-cocT-

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Table B 03/29/90 

YEAR 

PORT WASHINGTON POWER. PLANT 

MAY 1*709 FORECAST 

Units 1 - 4 

MEGAWATT FUEL CONSUHPTION 

HOURS CAPACITY COAL (13200 Btu/lb) 

GENERATED FACTOR BURNEO TONS YEAR 

' 1995 

1996 

1997 

1996 

1999 

2DD0 

2001 

2Q02 

20D3 

2004 

200S 

2006 

2007 

20DO 

2Q09 

825,288 

941,779 

1,061,002 

1,114,313 

1,247,296 

1,349,329 

1,391,B82 

1,401,464 

1,420,120 

1,432,122 

1,431.412 

1,460,471 

1,488,124 

1,481,423 

1,463,981 

0.29 

0.34 

0.39 

Q.4D 

Q.4S 

0.48 

a.SO 

a. 53 

Q.51 

0.51 

0.51 

0.52 

0.53 

0.53 

Q.52 

365,548 

415,332 

475,624 

49D»B60 

546,546 

589,569 

608,621 

646,417 

620,153 

625,174 

624,904 

637,519 

649,133 

646,909 

638,750 

PORT UASHINETON POUER PLANT 

UPPER MAXIMUM FORECAST 

Units 1- 4 

MEGAWATT FUEL CONSUMPTION 

HOURS CAPACITY COAL <13200 Btu/lb) 

GENERATEO FACTOR BURNED TONS 

3> 

C-I 

O 

•10 

1995 

1996 

1997 

1998 

1999 

2QO0 

2001 

20 02 

2003 

2004 

20Q5 

2006 

2007 

2D0B 

2009 

1,074,957 

1,202,460 

1,341,074 

1,390,470 

1,501,584 

1,600,500 

1,651,930 

1,740,046 

1,690,000 

1,690,000 

1,690,000 

1,710,000 

i.?20,aaa 

1,720,000 

1,695,000 

0.36 

D.43 

0.48 

0.50 

0.54 

0.57 

0.59 

0.6Z 

Q.60 

0.60 

0.60 

0.61 

0.61 

0.61 

0.60 

473,961 

52B,838 

SB7,412 

609,237 

654,718 

696,483 

718,252 

760,000 

735,aaa 

734,ODD 

734,000 

741,DOD 

748,000 

747,000 

737,000 

t-— 

C-4 

• • 

-JN 

4-

t-L 

o 

o K> 

o 

ho