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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

86) ll-C-28 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:55 AM Sheet 86 of 276 
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II-C-28 

> .A . \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

i REGION 5 o 

° VU/ ^ * 230 SOUTH DEARBORN ST. 

V r<^ CHICAGO, ILLINOIS 60604 

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S 3 Qa-si 133 ^ REPLY TO TH E ATTENTION OF: 

Donald F. Theiler, Director 

Bureau of Air Management 

Wisconsin Department of Natural Resources 

P.O. Box 7921 

Madison, Wisconsin 53707 

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Dear Mr. Theiler: =- \, \y 

This letter is in response to your inquiry of November 9, 1987, concerning the 

proposed renovations of Unit 1 through Unit 5 at the Port Washington (Ozaukee 

County) power plant of Wisconsin Electric Power Company (WEPCO). The inquiry 

raised a question of what the applicable baseline dates for the pollutants 

particulate matter (PM) and sulfur dioxide (SO2), and another question of how 

the provisions of prevention for significant deterioration (PSD) regulation 

apply to the proposed renovations. Our response to these questions is as 

follows: 

1. Baseline Dates 

For PM, the baseline date for Ozaukee County was triggered when the PSD 

application for WEPCO to construct a pressurized fluidized bed combustion 

(PFBC) boiler was determined to be complete on March 28, 1986. Although no 

PSD permit was issued for the PFBC boiler (WEPCO withdrew its application), 

the applicable baseline date remains in place because no change in date is 

authorized under the Clean Air Act. Section 169(4) of the Act establishes 

source application as the baseline triggering mechanism and does not qualify 

this mechanism by the later issuance of a permit (see 45 FR 52717). 

The WEPCO application did not trigger a baseline date for SO2 in Ozaukee County. 

The reason for this is that the PFBC project was intended to be a minor 

modification. The net emissions increase was restricted to less than the 

significant level due to a contemporaneous decrease of actual emissions provided 

by Unit 5 and to the plant-wide emissions cap [see 52.21(b)(14)(ii)]. 

2. Applicability of Federal Regulations 

The renovations at the Port Washington plant are extensive. They involve 

replacements, modifications, additions at the generating plant and improvements 

to plant availability, capability and heat rate. The renovations also include 

improvements to the precipitator (Project No. 13711) and an expected 40 percent 

increase of emissions over current plant capability. These renovations would 

extend the operating life of the units by more than 20 years beyond their 

planned retirement dates. 
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Your letter indicated that the renovations constitute an exempt modification 

under the State regulations [(reference: section 144.391(4)(b)2 of the 

Wisconsin statutes)]. We believe that these renovations could be subject to 

the Federal PSD regulations of 40 CFR 52.21 and the Federal new source 

performance standards (NSPS) of 40 CFR Part 60. For PSD, the applicable 

provisions are the modification provision of 52.21(b)(2) and its auxiliary 

definitions. For NSPS, the applicable provisions are section 60.14: 

modification and section 60.15: reconstruction. Within these provisions, 

exemptions are also defined. 

After a review of your Tetter, we find that it lacks adequate information 

to determine whether the renovations are subject to or exempt from the above 

provisions of the Federal regulations. Under the modification provisions, for 

example, the net emission change cannot be developed unless the impacts of the 

improvements to the precipitator and the increase in heat input rate are 

analyzed. Due to inadequate information, we are unable to give you a definitive 

answer on the applicability of these federally delegated regulations. We 

suggest that the Wisconsin Department of Natural Resources (WDNR), in its role 

as delegate agency, obtain the additional information from WEPCO and review it 

for the preceding Federal regulations. If a need remains, WDNR is welcome to 

reach us for further assistance. 

We appreciate the opportunity to respond to your inquiry. I trust this response 

is helpful. If you have questions on this letter, please call Rizalino Castanares 

of my staff at (312) 886-6047. If your question concerns NSPS, please contact 

Chae Pak of the Air Compliance Branch at (312) 886-6797. 

Sincerely yours, 

feve Rothblatt, Chief 

Air and Radiation Branch (SAR-26) 
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standard br.c's: official file copy w/attachnent(s) 

originator copy w/o attar.hment(s) 

originating organization reading file w/o attar.hnent(s) 

ORA reading file w/o attachment(s) 

other bcr.' s: 

Rothblatt 

Paisie 

MacDowell 

Van Mersbergen 

Koeber 

Castanares 

Pak, ACB 

File 

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