UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C.20460

Mr. John Boston

President

Wisconsin Electric Power Company

Post Office Box 2046

Milwaukee, Wisconsin 52301

Dear Mr. Boston:

On January 19, 1990, the United States Court of Appeals for the Seventh Circuit in

Wisconsin Electric Power Co. v. Reilly, Nos. 88-3264 and 89-1339, issued its decision regarding

a challenge by Wisconsin Electric Power Company (WEPCO) to two fmal determinations issued

by the Environmental Protection Agency (EPA). In these determinations, EPA concluded that

WEPCO’s proposed renovations to its Port Washington power plant would be subject to new

source performance standards (NSPS) and prevention of significant deterioration (PSD)

requirements.

In its decision, the court upheld all but one of the positions advanced by EPA in the NSPS

and PSD applicability determinations. However, the court rejected EPA’s position on the issue of

whether the “actual-to-potential” method--referred to by the court as the “potential to emit

concépt”--should be used to calculate emissions increases for PSD purposes in this case;

Consequently, the Seventh Circuit vacated and remanded the PSD determination to EPA for

further action consistent with the court’s decision.

As you know, EPA decided to acquiesce in the court’s holding rather than seek rehearing.

This letter constitutes EPA’s revised PSD applicability determination in response to the court’s

remand order.

The Agency believes that the court’s principal instruction--that EPA consider past

operating conditions at the plant when 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 of the court’s ruling is the recognition of a

subcategory of-”like- kind replacements” under the “major modification” defmition of EPA’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 that WEPCO wil 1 not be subject to PSD review for
2

sulfur dioxide (S02), particulate matter (PM), carbon monoxide, or hydrocarbons. However, there

will be a significant net increase in actual emissions of nitrogen oxides (NOx), and WEPCO must

obtain a PSD permit for that pollutant.

I. BACKGROUND

A. Factual Background.

The WEPCO owns and operates five coal-fired, steam-generating units at its Port

Washington facility near Milwaukee. All units had an original design capacity of 80 megawatts

when they were placed in service between 1935 and 1950. However, due to age-related

deterioration and loss of efficiency, both the physical capability and actual utilization of the plant

have declined over time. Unit 5 was shut down completely due to a cracked rear steam drum.

Consequently, by 1987, WEPCO was faced with removing the units from service as they reached

their planned retirement dates beginning in the early 1990’s, unless it undertook a costly “life

extension” program to restore the physical and economic viability ofthe units and extend their

useful life for approximately 20 years. The WEPCO proposed such a life extension to include

replacement of the steam drums, air heaters, and other major capital improvements totaling over

$80 million. It should be noted that this program is not a pollution control project (i.e., it is not

intended to add on or improve pollution control systems even though modest improvements to the

particulate matter control devices are a part of the program).

In a series of applicability determinations in 1988 and 1989, EPA ruled that the

renovations planned under WEPCO’s life extension program would constitute a “modification” for

purposes of the NSPS provisions of the Clean Air Act (Act), and a “major modification” under

the PSD provisions of the Act. Thus, WEPCO would have had to install some level of control

equipment or physical capacity restriction to avoid NSPS coverage for three of the five units

proposed to be renovated. As to PSD, the company would have had to accept operational

restrictions or lower emissions rates to “net out” of review. Regarding S02, for example,

WEPCO could haye almost doubled its projected level of future operations without triggering

PSD review. However, WEPCO did not want to be constrained by new source requirements, and

so sought review in the Seventh Circuit Court of Appeals.

B. The Court’s Decision.

1. Physical Change. V

The court unequivocally agreed with EPA that the replacement of steam drums, air

heaters, and other major components 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 exactly the type of industrial changes that were meant to

be addressed by the NSPS and PSD programs. In upholding EPA’s fmding that a physical change

would occur, the court strongly endorsed EPA’s reading of the basic congressional intent in

adopting the modification provisions of the NSPS and PSD programs, because to rule otherwise

“would open vistas of indefmite immunity from the provisions ofNSPS and PSD” (slip op. at 11).

The court also relied on the reasonableness of EPA’s consideration of the magnitude, purpose,

frequency, and cost of the work in upholding EPA’s fmding that the renovations are not “routine”

(slip op. at 14-18). In addition, the court rej ected WEPCO’s argument that the renovations could

not be deemed a modification for NSPS purposes because they did not constitute a

“reconstruction” under 40 CFR 60.15 (slip op. at 18-20).

2. NSPS Emissions Increase.

The court upheld EPA’s decision that there would be an increase in hourly emissions at

three of the units, and thus for those three units, WEPCO met the second test for NSPS

applicability. The Agency had argued that the regulations require NSPS emissions increases to be

determined by comparing the current (pre-change) hourly emissions capacity of each affected

facility with the post-renovation hourly emissions capacity of each unit. The Seventh Circuit

agreed, and rejected WEPCO’s argument that original design capacity or past “representative”

capacity no longer achievable at the plant should be used for the baseline emissions rate,(slip op.

at 20-25).

3. PSD Emissions Increase.

The regulatory preamble to the PSD regulations provides that the set of emissions units

that have “not begun normal operations” includes both “new or modified” 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 of WEPCO’s

“like- kind replacement,” asserting that EPA’s reasoning was circular (slip op. at 28). [Tn addition,

the court held (slip op. at 27 n. 11) that the exemption in 40 CFR 52.21 (b)(2)(iii)(f) for emissions

increases due to expanded operations did not apply, because WEPCO’s increased operations were

directly tied 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 of future emissions (slip op. at 29-31). Alternatively, the court stated that

EPA could conduct new rulemaking to explicitly apply the “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 not wholly disregard past operating history and

automatically apply the actual-to-potential methodology for determining PSD applicability to

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 of the actual-to-potential test to the full spectrum of new and modified

sources not covered by this subcategory of change. 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 of existing 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 that with Kiln No. 3”)]. A key issue was whether EPA properly held that the

“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 that the

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 of the 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 of EPA’s application of the actual-to-potential test to the full spectrum

of changes not covered by the subcategory of changes (like-kind replacements) created by the

court. {Footenote 1. } Therefore, in the case of nonroutine physical or operational changes at an

existing major source which are not specifically “like-kind replacements” in nature, EPA will

continue to apply the 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

for guidance ofthe parties, EPA presently considers that only for projects that are genuine “like-kind replacements” can

future emissions projections be calculated using. ‘estimated future actual emissions” in lieu of potential to emit. EPA

does not consider “like-kind~replacements” to mean the entire replacement (or reconstruction) of an existing emissions

unit with an identical new one or one similar in design or function. Rather, EPA considers “like-kind replacements” to

encompass the replacement of components at an emissions unit with the same (or functionally similar) components.

Under this 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 or purpose of a new component is identical to that of

an old one, ifthe new component is part of a project that will fundamentally change the production process at an

existing stationary source, this would be beyond the scope àf a “like-kind replacement.” Under either ofthose

circumstances, it would be unreasonable to rely on pre-modification usage patterns to estimate future levels of capacity

utilization. Instead, in such cases, EPA believes that it is reasonable to assume that in the absence of

federally-enforceable limits on hours of operation or production rates, the new components may result in a substantial

increase over historical levels of utilization ofthe emissions unit following modification [see Puerto Rican Cement,

supra, 889 F.2d at 297 (“a firm’s decision to introduce new, more efficient machinery may lead the firm to decide to

increase the level of production”)] 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, under certain circumstances, be exempt from new source review. See Letter to Timothy

3. Method, Assistant Coniniissioner, Indiana Department of Environmental 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 of actual emissions before a physical or operational

change is a necessary first step to determine if emissions increase as a result of the

physical change. The Agency’s regulations defme the baseline for PSD purposes, as follows:

In general, actual emissions as of a particular date shall equal the average rate, in

tons-per-year (tpy), at which the unit actually emitted the pollutant during a 2-year period

which precedes the particular date and which is representative of normal source V operation. The Administrator shall allow the use of a different time period upon a

determination that it is more representative of normal 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)(2 l)(ii)]. V The purpose of the definition is to establish a baseline that is “representative” of “normal”

source operations prior to the change. The Agency historically has followed a presumption

that the most recent 2 years should be used, but has allowed another period where the source

demonstrates that recent operations are abnormal [see 40 CFR 52.21 (b)(2 1 )(ii); see also 45 FR

52676, 52718 (1980)]. The WEPCO baseline period is an example of this. In this instance, plant

utilization was disrupted by physical problems that led to nonroutine physical changes

to remedy those problems. Consequently, EPA determined that a period prior to the onset of such

problems was representative of normal 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 emphasized that, in the WEPCO case, the

parties and the court agreed that 1983-84 (prior to discovery of steam 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 for the Port Washington renovation.

B. Calculating Post-Change Emissions Under PSD.

The court concluded that “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 at the plant, it also held

that EPA could not reasonably rely on the company’s own unenforceable projection of operating

conditions (slip op at 29). The court remanded the question of PSD applicability to EPA for

further proceedings not inconsistent with its decision.

Before the court remanded EPA’s determination, it attempted to ascertain whether, in fact, the

proposed project would be a major modification 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, of course, WEPCO’s own estimates of at least tripling of utilization over

current levels) (slip op. at 31, n. 14). The court, however, lacked the data to make this

calculation, so it could not determine whether a maj or modification would result using a set of

- assumptions most favorable to WEPCO. Therefore, the court remanded the determination to EPA

for further consideration.

A conceivable interpretation of the court’s opinion is that EPA must calculate WEPCO’s

post-modification emissions increases based on “present hours and conditions.” However, for the

reasons discussed below, EPA believes that this interpretation is incorrect. Under such an

interpretation, EPA would determine WEPCO’s post-renovation annual emissions in tons per year

(tpy) by simply projecting into the future the hours of operation and conditions (i.e., hourly

emissions rate) that existed just before the renovations. This is the interpretation urged by

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

same level of emissions before and after the physical change, and thus would always exempt

“like-kind replacements” from PSD review. In addition, calculating emissions increases using this

assumption would flatly contradict the record in this case. The WEPCO has stated that it will

greatly increase capacity utilization over both current levels and the baseline levels used in the

previous determinations. Capacity utilization in terms of heat input to 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, it was

approximately 27 percent. Id. It has since declined to less than 10 percent (1988-1989 data). Id.

The WEPCO has advised the State of Wisconin that it intends to return to a forecasted 42 percent

utilization level in the years following renovation, with an upper maximum forecast of 50 percent

[Letter from Walter Woelfie, WEPCO, to Dale Zeige, Wisconsin Department ofNatural

Resources, March 29, 1990, Table 7 (enclosed)]. It would be wrong to assume that unit 5 would

not be operated at all in the future when an explicit purpose of the 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 of the current regulations.

In addition, using “present hours and conditions” would disregard planned changes at WEPCO

that will affect the post-renovation hourly emissions rate [e.g., increased capacity, lowering of

sulfur content, and enhancement of the 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 court told EPA not to automatically assume 100 percent utilization

in the future when historical data are available. The WEPCO has defmite plans to return

the plant to historical levels of utilization that are well above baseline levels of utilization, and

which could not be physically or economically attained but for the renovation project.

Accordingly, EPA believes it is consistent with the court decision for EPA to base its remand

decision on these facts and not rely on the present hours and conditions as conclusive

of post-renovation emissions. After a thorough review of the possibilities, EPA has concluded that

the court intended that estimates of future emissions for WEPCO’s “like- kind replacements”

should consider historic pre-renovation operating hours and production rates, as well as other

relevant factors, in estimating future utilization levels, and should also consider the increased

capacity, switching to lower-sulfur fuel, and other changes affecting the hourly emissions rate for

PSD purposes. Consequently, for WEPCO’s “lilce-kjnd replacements,” EPA will compare

representative actual emissions for the 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 affect the 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 after the proposed changes EPA

relied heavily on projected and historical operational data (e.g., fuel consumption, MMBTU

consumed) representative of the 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 extent they are

or will be made federally enforceable) to estimate a future level of annual emissions for the

purpose of determining whether the proposed physical and operational changes would be

considered a major modification for PSD purposes. Where a significant emissions increase is

projected to occur, WEPCO could voluntarily agree to federally-enforceable limits on any aspect

of its future operation (including physical capacity and hours of operation) 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 Port Washington 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 plant will operate in

the future as it has in the past.

The stated purpose of WEPCO’s renovations is to refurbish the power plant units to an

“as-new” condition in terms of their capacity, efficiency, and availability. Consequently, EPA has

used actual, historical, operational data representative of the 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 of post- 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 consider them for

PSD applicability purposes.

Operational data (i.e., heat input) from the years 1978-1979 show a capacity utilization

factor of 42 percent. These data points represent the closest projection of WEPCO’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 of operation are representative of the

plant’s past operations in an “as-new” condition. In addition, the 1978-79 data points appear

consistent with WEPCO’s own projection of future operations for the year 2010 (as submitted to

the Wisconsin Department of Natural Resources on March 29, 1990) and common capacity levels

for the 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), if such data show heat

input levels notably higher than the 1978-1979 levels.
-9-

As previously mentioned, to calculate future emissions levels for each pollutant, EPA

assumed that the amount of future coal consumed in terms of heat input to the plant would 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 of future emissions for different levels of coal and heat input to the plant. The

Agency used these estimates to establish future emissions based on 1978-1979 heat-input values.

Again, it is important to note that EPA’s calculation of “estimated future actual emissions” is

based on WEPCO’s projection of control technology performance levels and/or fuel sulflE content

for post-renovation operations. Consequently, EPA’s PSD applicability determination is valid only

to the extent that the emissions factors (based on control technology performance levels and

sulfur in fuel) used to calculate future emissions are made federally enforceable. Otherwise, the

calculation of estimated future actual emissions for each pollutant will need to be revised by EPA

based on existing federally-enforceable limits (i.e., applicable SIP, NSPS). The use of current,

federally-enforceable emissions in the current SIP would result in higher projected future

emissions than assumed in EPA’s calculations and, consequently, could affect the indicated PSD

applicability fmding.

B. Revised Finding

In sum, EPA has considered past operations at WEPCO’s Port Washington plant in

estimating future actual emissions. Specifically, EPA has relied on the 42 percent utilization level

(in terms of heat input) during 1978-1979. The Agency believes this is a reliable indicator of

future utilization because it is consistent both with WEPCO’s own projections of post-renovation

operations and typical industry usage. The Agency has also considered post- renovation emissions

rates on the assumption that they will be made federally enforceable. Compared to the 1983-1984

baseline period, those hourly rates are lower for S02 and PM, and unchanged for NOx. The 42

percent estimated post-renovation capacity utilization is substantially higher than 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 by the decreased hourly emissions rates resulting

from improvements to control systems and the use of low sulfur coal. Consequently, WEPCO is

not subject to PSD review for those pollutants.
-10-

In the case of NOx, there will be a direct correlation between increased utilization

resulting from the renovations and increased actual emissions. Hence, WEPCO is subject to

review for that pollutant and must obtain a PSD permit. The company should contact the

Wisconsin Department ofNatural Resources regarding the processing of a permit application for

NOx. Due to insufficient source-specific information regarding emissions factors, PSD

applicability for PM- 10, lead, and noncriteria pollutants listed at 40 CFR 52.21 (b)(23)(i) and (ii)

cannot be determined at this time. The PSD applicability for these pollutants should also be based

on the “actual-to- actual” emissions test described herein.

This PSD applicability determination applies to WEPCO’s currently planned renovations

to units 1-5 (see Enclosure A), or, if WEPCO no longer wishes to proceed with renovating unit 5,

only the renovation of units 1-4 (see Enclosure B). However, a decision to cancel the currently

planned renovations to unit 5 could result in a PSD review for that unit should WEPCO

reconsider renovating 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 offset the

potential emissions increases of these pollutants. To the extent that the 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 for NOx. Unit 5 cannot, however, avoid

triggering NSPS for any pollutant and, therefore, is subject to the NSPS requirements for NOx,

S02, and PM.

Sincerely,

William G. Rosenberg

Assistant Administrator

for Air and Radiation

3 Enclosures
Table

7

PORT WASHINGTON 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

Units1-5

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

MEGAWATT
Enclosure A

Revised PSD Applicability Determination

Port Washin~ton Power Plant Renovation of Units 1-5

(all emissions calculations are in tons per year)

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

Sulfur dioxide (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 at 40 CFR Section 52.21 (b)(23)(i) and (ii) cannot be

determined at this time.

1) Average actual emissions for 2-year period defined by calendar years 1983 and 1984.

2) Calculated by EPA based on the following information submitted by WEPCO:

a. The avenge historic firing rate (approximately 17x106 Mbtu per year) for the 2-year period defined by

calendar years 1978 and 1979.

b. The emissions estimates for the renovated units based on future coal characteristics (e.g., sulfur and

heat content) and actual emissions after pollution controls for particulate.

c. Sulfur dioxide controls applied to unit 5 at 75 percent sulfur dioxide removal to comply with NSPS

Subpart Da. Sulfur dioxide removal of 22 and 13 percent at units 1 and 4, respectively, to exclude these

units from NSPS requirements for greater control of sulfur dioxide.

3) If new data indicate that annual, historic-firing rates at the Port Washington facility exceeded historic 1978 and

1979 levels, the indicated applicability determination could change.

4) The calculation of estimated, future, actual emissions for this pollutant is based on WEPCO’s projection of

control technology performance levels and/or fuel sulfur content for post-renovation operations. Consequently,

EPA’s PSD applicability determination is valid only to the extent that the specific particulate and sulfur dioxide

emissions factors used for units 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 for this pollutant will be revised by EPA, based on existing

federally-enforceable limits (i.e., applicable SIP, NSPS). The use of current, federally-enforceable emissions factors

would result in higher, projected, future emissions and, consequently, could affect the indicated PSD applicability

finding.

5) Baseline emissions (actual emissions for 2-year period defmed by calendar years 1983 and 1984) have been

revised based on additional information submitted by WEPCO.
Enclosure B

Revised PSD Applicability Determination

Port Washington Power Plant Renovation of Units 1-4

(all emissions calculations are in tons per year)

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 at 40 CFR Section 52.21 (b)(23)(i) and (ii) cannot be

determined at this time.

1) Average actual emissions for 2-year period defined by calendar years 1983 and 1984.

2) Calculated by EPA based on the following information submitted by WEPCO:

a. The average, historic-firing rate (approximately 17x106 Mbtu per year) for the 2-year period defined by

calendar years 1978 and 1979.

b. The emissions estimates for the renovated units based on future coal characteristics (e.g., sulfur and

heat content) and actual emissions after pollution controls for particulate.

c. Unit 5 inoperative. Sulfur dioxide removal of 22 and 13 percent at units 1 and 4, respectively, to

• exclude these units from NSPS requirements for greater control of sulfur dioxide.

3) If new data indicate that annual, historic-firing rates at the Port Washington facility exceeded historic 1978 and

1979 levels, the indicated applicability determination could change.

4) The calculation of estimated, future, actual emissions for this pollutant is based on WEPCO’s projection of

control technology performance levels and/or fuel sulfur content for post renovation operations. Consequently,

EPA’s PSD applicability determination is valid only to the extent that the specific particulate and sulfur dioxide

emissions factors used for units 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 for this pollutant will be revised by EPA, based on existing federally -

enforceable limits (i.e., applicable SIP, NSPS). The use of current, federally-enforceable emissions factors would

result in higher, projected, future emissions and, consequently, could affect the indicated PSD applicability fmding.

5) Baseline emissions (actual emissions for 2-year period defined by calendar years 1983 and 1984) have been

revised based on additional information submitted by WEPCO.