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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

162) ll-E-13 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:59 AM Sheet 162 of 276 
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II-E-13 

NOTE: Parts of this item are not legible. 
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Ul/i.C-'l^OJ • _ : i i. '•_ ."".<_•.<_. i i— <-* *. w - -

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION V 

17 JAN \m 

DATE: * 

Meeting with Wisconsin Elecxric: Power Company regarding the Port 

SUBJECT: Washington Generating station 

FROM: .David Schulz 

TO: 

Files 

Date of MPftHng. 

January 17, 1989 

Personnel Part: i c i -,-q L ::..;; 

f^JJLJtlll 

JUN 121991 

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David schulz - ".S. :I7., Region. V, ACB 

Deborah Djeu - U.S. :-PA, Region V, ORC 

Walter T . woeifie - WEPC O 

Terry coughlin - WEPCO 

Neil Childress - WEPC O 

Mark Steinberg - WEPCC 

Paul Schumacher - WEPCO 

Sally Farrell - U.S. -2Fh, SSCD (by telephone) 

David Solomon - U.S. EPA, NSRS (by telephone) 

Walt Stevenson - U.S. EPA , ES D (by telephone) 

Meeting Summary: 

The meeting was scheduled to discuss the results of anission and 

capacity testing completed by WEPCO at Port Washington units 1-4, and a 

new proposal by WEPCO for partial air heater replacement work on unit 

1. On January 12, 1989, I had provided by telephone an outline to 

WEPCO of test protocol aeficiencias we wished to discuss, as well as 

issues we would like than to respond to regarding the unit i air heater 

element replacement work. (<see attached conversation record). 

Following is a brief summary of responses provided by WEPCO during the 

meeting: 

Unit 1 - Particulate Violations - WEPCO indicated that they were 

surprised by the results of the first two particulate runs, wliich were 

veil above the allowable EM emission limitation. They contended Uiat 

the violations were due to turbine/governor control problems causing 

short term rapid fluctuations in the coal feed rate, Tfiey were not ^ 

able to provide information as to the frequency rate of this type of 

problem, or whether it was related to operation at higher than normal 

load on the unit. They also provided no information, as to why the last 

FM test run, after repairing the turbine/governor control problem, was 

also above the allowable FM limit. 
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* " .'" r 

2 -

unit 1 Ooacitv Violations - WEPCO contended that opacity violations 

on n/18 and 11/19 were due to .startup problans on the unit, and the 

problem with rlie turbine/governor controller. Opacity violations 

during the 5 day canonstration period were claimed to be due to early 

morning ramping, intermittent coal feeder problems, and a. one-time 

occurrence when rjie pulverized coal bin reached low levels due to 

operator oversight. 

Unit 1 - steam Drum ?ressurp Fwt&rtonrpzi - WEPCO contended tiiat the 

steam pressure exceedances were due to the accuracy of the meter used 

to adjust steam pressure and general directives given operators to 

"nominally*1 cont re i .^team pressure at a certain limit, rather than 

assuring that Oie steam pressure be safely retained below the .limit. 

Unit 2 - High rr-: Results on 3rd test run - WEPCO had no aSi.-eciiic 

explanation, i.-mcati.-.c. rnat it may have been due to short term surges 

in the coal feeoerc, r to variability in the testing procedure. 

Unit 2 - Steam ::rurr. .Yessure Exceedances - Same explanation as for 

unit l. 

Unit 3 - Opacity Violations - •-.'EPCO indicated that opacity violations 

during the 2nd PV tost run may nave been due to soot blowing. They 

indicated that opacity violations on. December 2, during the 5 day 

darrarstration period, were due to precipitator hopper ash buildup 

causing a tanporary short in the precipitator. They indicated that 

they subsequently increased the frequency of ash pulling from the 

precipitator toppers. 

tmit 3 - steam Dn m pressure Exceedances - Same explanation as J or 

units 1 & 2. 

Unit 4 - Particulate Violations - WEPCO contended that the very high 

particulate anission results on runs 1, 2 and 4 were, due to 

intermittent feedwater control problems. Tliey were unable to provide 

information regarding the frequency of this type of problan, or whether 

it could be related to operation at higher than normal load on the 

unit. With regard to the test run that was cancelled due to wire 

breakage shorting the precipitator, and an earlier problem the week 

before, resulting in. a delay of testing due to ESP wire breaicage, WEPCO 

was unable to provide information regarding the frequency of such, 

problons on tlie unit, or whether it could be related to operation at 

higher than normal load on the unit. 

unit 4 Opacity Violations - WEPCO contended, that opacity violations 

recorded during the 5-day demonstration period may have been due to 

intermittent problems witii the coal feeder controller, but were unable 

to document that as the cause, or provide any information a-s to the 

frequency of occurrence of such a problan. 
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Unit 4 - steam Cnra Pressure - WEPCO vas unable to provide any clear 

explanation as to why this unit vas held below its designated pressure 

limitation, while the other 3 units were not. 

Unit J. ~ air Heater Partial RQpiacanent - WEPCO contended thai-, tlie 

proposed air heater element replacement should be considered "routine 

maintenance". AS support for this position, they provided a list of 

approximately 40 other utility units for which they contended air 

iieater eianent cr complete replacement had been done. PaOwever, upon 

quastioning, WEPCO admitted tiiat unit 1, now 54 years old, and units 2-

4 (40-46 years old), ;iave never had any replacement of the air heaters, 

or air heater elements. WEPCO indicated tiiat tiie cost of this proposed 

replacement work would be $500,000 - $550,000. They also indicated 

that if they completed this work now they would likely keep those 

elements replaced .tr- •~.QV , and replace the remainder as part of the 

total project at ... .ater date. This statanent was different than WEPCO 

had indicated d-.irir.a telephone discussions on January 12, .989 (see 

attached conversation record). WEPCO indicated tiiat they did nor. know 

if the replacement ot 50% of the air heater elements (as propo.;..'.> 

would result ir. a capacity increase on the unit. However, they did 

indicate that canpiete replacement of the air heater elements on unit 1 

.should result; in an increase in capacity to its original design. 

U.S. KPA agreed tc respond to WEPCO on tliese issues as soon as 

possible. 

Attachment-. 

cc: Farrell, SSCD 

Stevenson, ESD 

Solomon, NSR 

Foote, OGC 

Kee 

Kertcher 

Spyropoulos 

Van Mersbergen 

Djeu 
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