UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D.C.20460

Mr. John Boston President Wisconsin Electric Power Company Post Office Box2046 Milwaukee, Wisconsin 52301

Dear Mr. Boston:

On January 19, 1990, the United States Court ofAppeals forthe Seventh Circuit in Wisconsin Electric Power Co. v. Reilly, Nos. 88-3264 and 89-1339, issued its decision regarding
a challenge byWisconsin Electric Power Company (WEPCO) to two fmal determinations issued bythe Environmental Protection Agency (EPA). In these determinations, EPA concludedthat WEPCO’s proposed renovations to its Port Washington powerplantwould be subjectto new source performance standards (NSPS) and prevention ofsignificant deterioration (PSD) requirements.

In its decision, the court upheld all but one ofthe positions advanced by EPA in the NSPS and PSD applicability determinations. However, the court rejected EPA’s position onthe issue of whetherthe “actual-to-potential” method--referred to bythe court as the “potential to emit concépt”--should be used to calculate emissions increases for PSD purposes in this case; Consequently, the Seventh Circuitvacated and remanded the PSD determination to EPA for further action consistentwith the court’s decision.

As you know, EPA decided to acquiesce in the court’s holding ratherthan seekrehearing. This letter constitutes EPA’s revised PSD applicability determination in responseto the court’s remand order.

The Agency believes thatthe court’s principal instruction--that EPA considerpast operating conditions atthe plantwhen addressing modifications that involve “like-kind replacements”--can be reasonably accommodated within the present regulatory framework without further litigation in this case. The net result ofthe court’s ruling is the recognition ofa subcategory of-”like- kind replacements” underthe “major modification” defmition ofEPA’s new source review provisions.

As explained below, EPA will employ an “actual-to-actual” method to calculate emissions increases for WEPCO’s proposed renovations to its Port Washington power plant. The outcome in this case is thatWEPCO wil 1 not be subject to PSD review for2

sulfur dioxide (S02), particulate matter (PM), carbon monoxide, or hydrocarbons. However, there will be a significant net increase in actual emissions ofnitrogen oxides (NOx), and

### WEPCO must obtain a PSD permit forthat pollutant.

I. BACKGROUND

A. Factual Background.

The WEPCO owns and operates five coal-fired, steam-generating units at its Port Washington facility nearMilwaukee. All units had an original design capacity of80 megawatts when theywere placed in service between 1935 and 1950. However, due to age-related deterioration and loss ofefficiency, both the physical capability and actual utilization ofthe plant have declined overtime. Unit 5 was shut down completely due to a cracked rear steam drum. Consequently, by 1987, WEPCO was faced with removingthe units from service as they reached theirplanned retirement dates beginning in the early 1990’s, unless it undertook a costly “life extension” program to restore the physical and economicviability ofthe units and extend their useful life for approximately 20 years. TheWEPCO proposed such a life extension to include replacement ofthe steam drums, air heaters, and other majorcapital improvementstotaling over $80 million. It should be noted thatthis program is not a pollution control project (i.e., it is not intendedto add on or improve pollution control systems even though modest improvements to the particulate matter control devices are a part ofthe program).

In a series ofapplicability determinations in 1988 and 1989, EPA ruled thatthe renovations planned underWEPCO’s life extension program would constitute a “modification” for purposes ofthe NSPS provisions ofthe Clean AirAct (Act), and a “major modification” under the PSD provisions ofthe Act. Thus, WEPCO would have had to install some level ofcontrol equipment orphysical capacity restriction to avoid NSPS coverage forthree ofthe five units proposed to be renovated. As to PSD, the company would have had to accept operational restrictions or loweremissions rates to “net out” ofreview. Regarding S02, for example, WEPCO could haye almost doubled its projected level offuture operations withouttriggering PSD review. However, WEPCO did not wantto be constrained by new source requirements, and
so sought review in the Seventh Circuit Court ofAppeals.

B. The Court’s Decision.

1. Physical Change. V
The court unequivocally agreed with EPAthatthe replacement ofsteam drums, air heaters, and other majorcomponents was a nonroutine “physical change,” and thus met the first of two tests for a modification under NSPS and PSD. The Agency found that the

### 3

renovations proposed by

### WEPCO were exactlythe type ofindustrial changes thatwere meantto be addressed bythe NSPS and PSD programs. In upholding EPA’s fmding that a physical change would occur, the court strongly endorsed EPA’s reading ofthe basic congressional intent in adoptingthe modification provisions ofthe NSPS and PSD programs, because to rule otherwise “would openvistas ofindefmite immunity from the provisions ofNSPS and PSD” (slip op. at 11). The court also relied on the reasonableness ofEPA’s consideration ofthe magnitude, purpose, frequency, and cost ofthe work in upholding EPA’s fmding that the renovations are not “routine” (slip op. at 14-18). In addition, the court rejected WEPCO’s argumentthatthe renovations could not be deemed a modification forNSPS purposes because they did not constitute a “reconstruction” under40 CFR 60.15 (slip op. at 18-20).

2. NSPS Emissions Increase.

The court upheld EPA’s decision thatthere would be an increase in hourly emissions at three ofthe units, and thus forthose three units, WEPCO met the secondtest forNSPS applicability. The Agency had arguedthatthe regulations require NSPS emissions increases to be determined by comparing the current (pre-change) hourly emissions capacity ofeach affected facilitywith the post-renovation hourly emissions capacity ofeach unit. The Seventh Circuit agreed, and rejected WEPCO’s argumentthat original design capacity orpast “representative” capacity no longerachievable atthe plant should be used forthe baseline emissions rate,(slip op. at 20-25).

3. PSD Emissions Increase.

The regulatorypreamble to the PSD regulations provides thatthe set ofemissions units that have “not begun normal operations” includes both “new ormodified” units (45 

### FR 52676, 52677, 52718) (1980). Consequently, EPA used the “actual-to-potential” calculus in evaluating WEPCO’s life extension project. The court rejected this methodology in the case ofWEPCO’s “like- kind replacement,” asserting that EPA’s reasoning was circular (slip op. at28). [Tn addition, the court held (slip op. at 27 n. 11) thatthe exemption in 40 CFR 52.21 (b)(2)(iii)(f) for emissions increases due to expanded operations did not apply, becauseWEPCO’s increased operationswere directlytied to the life extension project.] Instead, the court ruled that EPA should recalculate post-change emissions considering past operating conditions where it is possible to make a more realistic assessment offuture emissions (slip op. at29-31). Alternatively, the court stated that EPA could conduct new rulemaking to explicitly applythe “actual-to-potential” calculus to “like-kind replacements” (slip op. at 30).4

II.~THE WEPCO DECISION IN THE CONTEXT OF THE PSD PROVISIONS

The Seventh Circuit held that EPA could notwholly disregard past operating history and automaticallyapplythe actual-to-potential methodology for determining PSD applicabilityto WEPCO’s “like-kind replacements.” In describing the WEPCO changes as “like-kind replacements” and limiting its decision to such changes, the court did not dispute the correctness ofEPA’s application ofthe actual-to-potential testto the full spectrum ofnew and modified

sources not covered bythis subcategory ofchange. The recent decision in Puerto Rican Cement Co. v. EPA, 889 F.2d 292 (1st Cir. 1989); explicitly upheld EPA’s position that the actual-to-potential concept should be applied to “modified” emissions units. The First Circuit

case involved the modernization and reconfiguration ofexisting emissions units [see 889 F.2d at 293 (company planned to “convert kiln No., 6 from a ‘wet’ tà a ‘dry’ cement- making process, and to combine thatwith Kiln No. 3”)]. A key issue was whetherEPA properly held thatthe “modified” units had “not begun normal operation” and therefore the actual-to-potential concept applied in calculating emissions increases. The First Circuit affirmed EPA’s position thatthe actual-to-potential concept should be applied to the company’s “modified” units. Puerto Rican Cement, 889 F.2d at 297. Consequently, the court found that both the language and expressed purpose ofthe regulations indicate that EPA applied the regulations properly in using the actual-to- potential test for a proposed modification. The Seventh Circuit in WEPCO did not dispute the correctness ofEPA’s application ofthe actual-to-potential testto the full spectrum ofchanges not covered bythe subcategoryofchanges (like-kind replacements) created bythe court. {Footenote 1.

## } Therefore, in the case ofnonroutine physical or operational changes at an existing majorsourcewhich are not specifically “like-kind replacements” in nature, EPAwill continue to applythe actual-to-potential test for PSD applicability purposes. j/• EPA will leave to future case by case applicability determinations what is a “like-kind replacement.” But forguidance ofthe parties, EPA presently considers that only forprojects that are genuine “like-kind replacements” can future emissions projections be calculated using. ‘estimated future actual emissions” in lieu ofpotential to emit. EPA does not consider “like-kind~replacements” to mean the entire replacement (or reconstruction) ofan existing emissions unitwith an identical new one or one similar in design orfunction. Rather, EPA considers “like-kind replacements” to encompass the replacement ofcomponents at an emissions unitwith the same (orfunctionally similar) components. Underthis interpretation ofthe term, new components that perform essentially the same function as old ones will be viewed as “like-kind replacements.” In addition, even ifthe design orpurpose ofa new component is identical to that of an old one, ifthe new component is part ofa projectthatwill fundamentally change the production process at an existing stationary source, this would be beyond the scope àfa “like-kind replacement.” Under either ofthose circumstances, itwould be unreasonable to rely on pre-modification usage patterns to estimate future levels ofcapacity utilization. Instead, in such cases, EPA believes that it is reasonable to assume that in the absence of federally-enforceable limits on hours ofoperation orproduction rates, the new components may result in a substantial increase over historical levels ofutilization ofthe emissions unit following modification [see Puerto Rican Cement, supra, 889 F.2d at297 (“a firm’s decision to introduce new, more efficient machinery may lead the firm to decide to increase the level ofproduction”)] and will compare pre-modification actual emissions to post-modification potential emissions. In addition to this circumstance, there are cases in which sources that undergo changes that qualify as add-on control systems would, undercertain circumstances, be exempt from new source review. See Letterto Timothy 3. Method, Assistant Coniniissioner, Indiana Department ofEnvironmental Mana-gement, from David Kee, EPA Region V, January 30, 1990.-5-

III. THE AGENCY’S RESPONSE TO THE COURT’S REMAND ORDER

A. The PSD Baseline Emissions.
Determining the “baseline” level ofactual emissions before a physical or operational change is a necessary first step to determine ifemissions increase as a result ofthe physical change. TheAgency’s regulations defme the baseline for PSD purposes, as follows:

In general, actual emissions as ofa particular date shall equal the average rate, in tons-per-year (tpy), atwhich the unit actually emitted the pollutant during a2-yearperiod which precedes the particular date and which is representative ofnormal source V operation. The Administrator shall allow the use ofa differenttime period upon a determination that it is more representative ofnormal source operation. Actual emissions V shall be calculated using the unit’s actual operating hours, production rates, and types of materials processed, stored, or combusted during the selected time period [see 40 CFR 52.21 (b)(2l)(ii)]. V
The purpose ofthe definition is to establish a baselinethat is “representative” of“normal”
source operations priorto the change. The Agency historicallyhas followed a presumption thatthe most recent 2 years should be used, but has allowed anotherperiod where the source demonstrates that recent operations are abnormal [see 40 CFR 52.21 (b)(21)(ii); see also 45 FR 52676, 52718 (1980)]. The WEPCO baseline period is an example ofthis. In this instance, plant utilization was disrupted byphysical problemsthat led to nonroutine physical changes to remedythose problems. Consequently, EPA determinedthat a period priorto the onset ofsuch problemswas representative ofnormal operations, and as required by its regulations, used this V period to establish the baseline. The period used was also within the contemporaneous period specified in 40 CFR 52.21 (b)(3)(ii). It should be emphasizedthat, in the WEPCO case, the parties and the court agreed that 1983-84 (priorto discovery ofsteam drum cracks) should be the baseline years (slip op. at 26); these years had an average 29 percent utilization rate. We continue to believe this is the appropriate baseline period forthe PortWashington renovation.

B. Calculating Post-Change Emissions Under PSD.

The court concludedthat “EPA’s reliance on an assumed continuous operation as a basis for finding an emissions increase is not properly supported” (slip op. at 30). Although the court held that EPA cannot, in this case, wholly disregard past operating conditions atthe plant, it also held that EPA could not reasonably rely onthe company’s own unenforceable projection ofoperating conditions (slip op at 29). The court remanded the question ofPSD applicabilityto EPA for furtherproceedings not inconsistentwith its decision.

Before the court remanded EPA’s determination, it attempted to ascertain whether, in fact, the proposed projectwould be a majormodification even using the assumptions least likely to result in an emissions increase. The court felt (and we agree) that such a “best” case scenario for-6-



### WEPCO would assume that the “present hours and conditions” would not change at all following the renovations (despite, ofcourse, WEPCO’s own estimates ofat least tripling ofutilization over current levels) (slip op. at 31, n. 14). The court, however, lacked the data to make this calculation, so it could not determine whethera majormodificationwould result using a set of

- assumptions most favorable to WEPCO. Therefore, the court remandedthe determination to EPA forfurther consideration.

A conceivable interpretation ofthe court’s opinion is that EPA must calculate WEPCO’s post-modification emissions increases based on “present hours and conditions.” However, forthe

reasons discussed below, EPA believes thatthis interpretation is incorrect. Under such an interpretation, EPAwould determine WEPCO’s post-renovation annual emissions in tons peryear (tpy) by simply projecting into the future the hours ofoperation and conditions (i.e., hourly emissions rate) that existedjustbefore the renovations. This is the interpretation urged by 

### WEPCO in a February 9, 1990 letterto EPA. Such a calculus will always result in exactly the

same level ofemissions before and afterthe physical change, and thus would always exempt “like-kind replacements” from PSD review. In addition, calculating emissions increases using this assumption would flatly contradictthe record in this case. The WEPCO has stated that itwill greatly increase capacity utilization overboth current levels and the baseline levels used in the previous determinations. Capacity utilization in terms ofheat inputto the plant (based on nameplate capacity) during 1978-1979 was about 40 percent (Record item 7.4, WEPCO Submission, April 19, 1988 meeting with EPA). During the 1983-1984 baseline period, itwas approximately27 percent. Id. It has since declined to less than 10 percent (1988-1989 data). Id. The WEPCO has advised the State ofWisconin that it intends to return to a forecasted 42 percent utilization level in the years following renovation, with an upper maximum forecast of50 percent [Letterfrom WalterWoelfie, WEPCO, to Dale Zeige, Wisconsin Department ofNatural Resources, March 29, 1990, Table 7 (enclosed)]. Itwould bewrong to assume that unit 5 would notbe operated at all in the future when an explicit purpose ofthe renovation is to bring the unit back on line at its original design capacity; moreover, unit 5 is presently inoperative. Most importantly, this methodology is not fairly discernible from any reading ofthe current regulations. In addition, using “present hours and conditions” would disregard planned changes atWEPCO thatwill affectthe post-renovation hourly emissions rate [e.g., increased capacity, lowering of sulfur content, and enhancement ofthe electrostatic precipitators (ESP)].

The court upheld EPA’s position that increased utilization in the future that is linked to construction or modification activity should not be excluded in determining post-renovation-7-

emissions. Nevertheless, the courttold EPA not to automatically assume 100 percent utilization in the future when historical data are available. TheWEPCO has defmite plans to return the plantto historical levels ofutilization that are well above baseline levels ofutilization, and which could not be physically or economically attained but forthe renovation project. Accordingly, EPAbelieves it is consistentwith the court decision for EPAto base its remand decision on these facts and not rely onthe present hours and conditions as conclusive ofpost-renovation emissions. After athorough review ofthe possibilities, EPA has concluded that the court intended that estimates offuture emissions forWEPCO’s “like- kind replacements” should consider historic pre-renovation operating hours and production rates, as well as other relevantfactors, in estimating future utilization levels, and should also considerthe increased capacity, switching to lower-sulfurfuel, and otherchanges affecting the hourly emissions rate for PSD purposes. Consequently, forWEPCO’s “lilce-kjnd replacements,” EPAwill compare representative actual emissions forthe baseline period to estimated future actual emissions based

on all the available facts in the record. Specifically, in calculating post-renovation actual emissions, this approach takes into account 1) physical changes and operational restrictions that would affectthe hourly emissions rate following the renovation, 2) WEPCO’s pre-renovation capacity utilization, and 3) factors affecting WEPCO’s likely post-renovation capacity utilization.

To quantify WEPCO’s estimated future actual emissions afterthe proposed changes EPA relied heavily on projected and historical operational data (e.g., fuel consumption, MMBTU consumed) representative ofthe source. Specifically, the Agency considered available information regarding (1) projected post- change capacity utilization filed with public utility commissions; (2) Federal and State regulatory filings; (3) the source’s own representations; and (4) the source’s historical operating data. As described below, EPA determined an appropriate utilization factor for future operations and combined this with post-change emissions factors (to the extentthey are
orwill be made federally enforceable) to estimate a future level ofannual emissions forthe purpose ofdetermining whetherthe proposed physical and operational changes would be considered a majormodification for PSD purposes. Where a significant emissions increase is projected to occur, WEPCO could voluntarily agree to federally-enforceable limits on any aspect ofits future operation (including physical capacity and hours ofoperation) to ensure that no significant emissions increase will occur.

--8-

IV. THE AGENCY’S REVISED PSD APPLICABILITY DETERMiNATION

A. Estimated Future Actual Emissions.

The Agency has revised its October 14, 1989 PSD applicability determination for WEPCO’s proposed PortWashington renovation based on a “representative actual” to “estimated future actual emissions” comparison (as outlined above). As previously discussed, estimated future actual emissions projections take into account the likelihood that the plantwill operate in the future as it has in the past.

The stated purpose ofWEPCO’s renovations is to refurbish the power plant units to an “as-new” condition in terms oftheir capacity, efficiency, and availability. Consequently, EPA has used actual, historical, operational data representative ofthe plant’s past operations, approximating an “as-new” configuration, to calculate “estimated future actual emissions.” The Agency has verified these data by comparison to WEPCO’s own projections ofpost- renovation capacity utilization and industry averages.

As to the emissions factors used to calculate future emissions, EPA has used WEPCO’s

own emissions factors for future hourly emissions rates. These emissions factors are based on WEPCO’s own assumptions regarding future sulfur in fuel and control technology performance levels. However, since these assumptions go beyond current State implementation plan (SIP) requirements, they must be made federally enforceable for EPA to continue to considerthem for PSD applicability purposes.

Operational data (i.e., heat input) from the years 1978-1979 show a capacity utilization factor of42 percent. These data points represent the closest projection ofWEPCO’s operational characteristics, approximating an “as-new” state, as currently available to EPA. The data currently available to us regarding WEPCO’s past operational levels are limited to a 10-year period. The Agency believes that these historical levels ofoperation are representative ofthe plant’s past operations in an “as-new” condition. In addition, the 1978-79 data points appear consistent with WEPCO’s own projection offuture operations forthe year 2010 (as submitted to the Wisconsin Department ofNatural Resources on March 29, 1990) and common capacity levels forthe utility industry, in general, for new units. However, by this letter, EPA is requesting that WEPCO submit operational data from previous years (i.e., pre-1978), ifsuch data show heat input levels notably higherthan the 1978-1979 levels.-9-

As previously mentioned, to calculate future emissions levels foreach pollutant, EPA assumed that the amount offuture coal consumed in terms ofheat inputto the plantwould be comparable to WEPCO’s annual average 1978- 1979 coal-consumption figure. On March 29, 1990, WEPCO submitted to the Wisconsin Department ofNatural Resources information which contained estimates offuture emissions for different levels ofcoal and heat inputto the plant. The Agencyused these estimates to establish future emissions based on 1978-1979 heat-inputvalues. Again, it is importantto note that EPA’s calculation of“estimated future actual emissions” is based onWEPCO’s projection ofcontrol technology performance levels and/orfuel sulflE content forpost-renovation operations. Consequently, EPA’s PSD applicability determination is valid only to the extentthatthe emissions factors (based on control technologyperformance levels and sulfur in fuel) used to calculate future emissions are made federally enforceable. Otherwise, the calculation ofestimated future actual emissions for each pollutant will needto be revised by EPA based on existing federally-enforceable limits (i.e., applicable SIP, NSPS). The use ofcurrent, federally-enforceable emissions in the current SIP would result in higherprojected future emissions than assumed in EPA’s calculations and, consequently, could affectthe indicated PSD applicabilityfmding.

B. Revised Finding

In sum, EPA has considered past operations atWEPCO’s Port Washington plant in estimating future actual emissions. Specifically, EPA has relied on the 42 percent utilization level (in terms ofheat input) during 1978-1979. The Agencybelieves this is a reliable indicatorof future utilization because it is consistent both with WEPCO’s own projections ofpost-renovation operations and typical industry usage. The Agency has also considered post- renovation emissions rates on the assumption that theywill be made federally enforceable. Compared to the 1983-1984 baseline period, those hourly rates are lowerfor S02 and PM, and unchanged forNOx. The 42 percent estimated post-renovation capacity utilization is substantiallyhigherthan the 29 percent utilization level during the baseline period. However, in calculating total annual actual emissions, that increased usage is offset for S02 and PM bythe decreased hourly emissions rates resulting from improvements to control systems and the use oflow sulfur coal. Consequently, WEPCO is not subjectto PSD review forthose pollutants.-10-

In the case ofNOx, there will be a direct correlation between increased utilization resulting from the renovations and increased actual emissions. Hence, 

### WEPCO is subjectto review forthat pollutant and must obtain a PSD permit. The company should contactthe Wisconsin Department ofNatural Resources regarding the processing ofa permit application for NOx. Due to insufficient source-specific information regarding emissions factors, PSD applicability for PM-10, lead, and noncriteriapollutants listed at40 CFR 52.21 (b)(23)(i) and (ii) cannot be determined atthis time. The PSD applicability forthese pollutants should also be based

onthe “actual-to- actual” emissions test described herein.

This PSD applicability determination applies to WEPCO’s currentlyplanned renovations to units 1-5 (see Enclosure A), or, ifWEPCO no longerwishes to proceedwith renovating unit 5, onlythe renovation ofunits 1-4 (see Enclosure B). However, a decisionto cancel the currently planned renovations to unit 5 could result in a PSD review forthat unit should WEPCO reconsiderrenovating it some time in the future.

It is our understanding that WEPCO proposes to avoid triggering NSPS for 502 and PM at units 1 and 4 by using dry sorbent injection and improving the existing ESP’s to offsetthe potential emissions increases ofthese pollutants. To the extentthatthe controls are federally enforceable, and no increase in hourly emissions would occur at maximum capacity, WEPCO can
use these options to avoid triggering NSPS for PM and 502 at units 1 and 4. However, the two units are still subject to the NSPS requirements forNOx. Unit 5 cannot, however, avoid triggering NSPS for anypollutant and, therefore, is subjectto the NSPS requirements forNOx, S02, and PM.

Sincerely,

William G. Rosenberg Assistant Administrator forAir and Radiation

3 EnclosuresTable 7
PORTWASHINGTON POWER PLANT MAY 1989 FORECAST Uriitsl-5

YEAR 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 HOURS

GENERATED 825,288 941,779 1,081,002 1,114,313 1,247,296 1,349,329 1,391,882 1,481,464 1,420,120 1,432,122 1,431,412 1,460,471 1,488,124 1,481,423 1,463,981 FUEL

CONSUMPTION CAPACITY FACTOR 0.24 0.27 0.31 0.32 0.36 0.38 0.40 0.42 0~41 0.41 0.41 0.42 0.42 0.42 0.42 COAL (13200 Btu/lb)

BURNED TONS 365,548 415,332 475,624 490,868 546,546 589,569 608,621 646,417 620,153 625,174 624,904 637,519 649,133 646,909 638,750
PORT WASHINGTON POWER PLANT UPPER MAXIMUM FORECAST

Units 1

- 5

YEAR 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 MEGAWATT

HOURS GENERATED 1,074,957 1,202,460 1,341,074 1,390,470 1,501,584 1,600,500 1,651,930 1,748,046 1,690,000 1,690,000 1,690,000 1,710,000 1,720,000 1,720,000 1,695,000 FUEL CAPACITY FACTOR 0.24 0.27 0.38 0.40 0.43 0.46 0.47 0.50 0.48 0.48 0.48 0.49 0.49 0.49 0.48 CONSUMPTION

COAL (13200 BtuJlb) BURNED TONS 473,981 528,838 587,412 609,237 654,718 696,483 718,252 760,000 735,000 734,000 734,000

• 741,000 748,000 747,000 737,000 MEGAWATTEnclosure A
Revised PSD Applicability Determination PortWashin~ton Power Plant Renovation ofUnits 1-5 (all emissions calculations are in tons peryear)

Estimated Actual Future Net PSD Subject Emissions Actual Emissions Significance to PSD Pollutant Baseline

### LU Emissions(2) Change Level Review

Particulate matter (4) (5) 328 323 -5 25 no
Sulfurdioxide (4) 24,236 15,919 -8,317 40 no Nitrogen oxides (5) 2,592 3,405 813 40 yes
Carbon monoxide 144 217 73 

### 100 no Hydrocarbon 17 25 9 40 no

Other Regulated Pollutants: Due to insufficient source-specific information regarding emission factors, PSD applicability for PM-b, lead and noncriteria pollutants listed at40 CFR Section 52.21 (b)(23)(i) and (ii) cannot be determined atthis time. 1) Average actual emissions for2-yearperiod defined by calendaryears 1983 and 1984. 2) Calculated by EPA based on the following information submitted by WEPCO:

a. The avenge historic firing rate (approximately 17x106 Mbtu peryear) forthe 2-year period defined by calendaryears 1978 and 1979.

b. The emissions estimates forthe renovated units based on future coal characteristics (e.g., sulfurand heat content) and actual emissions after pollution controls forparticulate.

c. Sulfurdioxide controls applied to unit 5 at 75 percent sulfur dioxide removal to comply with NSPS Subpart Da. Sulfur dioxide removal of22 and 13 percent at units 1 and 4, respectively, to exclude these units from NSPS requirements forgreater control ofsulfur dioxide. 3) Ifnew data indicate that annual, historic-firing rates atthe PortWashington facility exceeded historic 1978 and 1979 levels, the indicated applicability determination could change. 4) The calculation ofestimated, future, actual emissions forthis pollutant is based on WEPCO’s projection of control technology performance levels and/orfuel sulfur content forpost-renovation operations. Consequently, EPA’s PSD applicability determination is valid only to the extentthatthe specific particulate and sulfur dioxide emissions factors used forunits 1-5 to calculate future emissions (based on particulate and S02 control technology performance levels and fuel sulfur and heat content) are made fedenlly enforceable. Otherwise, the calculation of estimated, future, actual emissions forthis pollutantwill be revised by EPA, based on existing federally-enforceable limits (i.e., applicable SIP, NSPS). The use ofcurrent, federally-enforceable emissions factors would result in higher, projected, future emissions and, consequently, could affectthe indicated PSD applicability finding. 5) Baseline emissions (actual emissions for 2-yearperiod defmed by calendaryears 1983 and 1984) have been revised based on additional information submitted by WEPCO.Enclosure B

Revised PSD Applicability Determination PortWashington Power Plant Renovation ofUnits 1-4 (all emissions calculations are in tons peryear)

Estimated Actual Future Net PSD Subject Emissions Actual Emissions Significance to PSD Pollutant Baseline

### W Emissions(2~ Change Level Review

Particulate matter (4) (5) 328 339 11 25 no
Sulfur dioxide (4) 24,236 18,505 -5,731 40 no Nitrogen oxides (5) 2,592 3,396 804 40 yes
Carbon monoxide 144 217 73 100 no Hydrocarbon 17 25 9 40 no

Other Regulated Pollutants: Due to insufficient source specific information regarding emission factors, PSD applicability for PM-b, lead and noncriteria pollutants listed at40 CFR Section 52.21 (b)(23)(i) and (ii) cannotbe determined atthis time. 1) Average actual emissions for2-year period defined by calendaryears 1983 and 1984. 2) Calculated by EPA based on the following information submitted by WEPCO:

a. The average, historic-firing rate (approximately 17x106 Mbtu peryear) forthe 2-yearperiod defined by calendaryears 1978 and 1979.

b. The emissions estimates forthe renovated units based on future coal characteristics (e.g., sulfur and heat content) and actual emissions afterpollution controls for particulate.

c. Unit 5 inoperative. Sulfur dioxide removal of22 and 13 percent at units 1 and 4, respectively, to

• exclude these units from NSPS requirements forgreater control ofsulfur dioxide. 3) Ifnew data indicate that annual, historic-firing rates atthe PortWashington facility exceeded historic 1978 and 1979 levels, the indicated applicability determination could change. 4) The calculation ofestimated, future, actual emissions forthis pollutant is based on WEPCO’s projection of control technology performance levels and/orfuel sulfur content for post renovation operations. Consequently, EPA’s PSD applicability determination is valid only to the extentthatthe specific particulate and sulfur dioxide emissions factors used forunits 1-4 lo calculate future emissions (based on particulate and S02 control technology performance levels and fuel sulfur and heat content) are made federally enforceable. Otherwise, the calculation of estimated, future, actual emissions forthis pollutantwill be revised by EPA, based on existing federally

- enforceable limits (i.e., applicable SIP, NSPS). The use ofcurrent, federally-enforceable emissions factors would result in higher, projected, future emissions and, consequently, could affectthe indicated PSD applicability fmding. 5) Baseline emissions (actual emissions for2-yearperiod defined by calendaryears 1983 and 1984) have been revised based on additional information submitted by WEPCO.