P.1 

OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

48) ll-B-23 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:53 AM Sheet 48 of 276 
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II-B-23 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION V __ ._ — -,;;- " 

SUBJECT: WEPCcQ>Port Washington Test Results 'jJUj M \ ? ,0QI 

David Schulz, Power Plant Expert I ±1 . AID DOC& 

FROM: compliance Section I | FFAAinuw 

TO:

 FUe S 

I have reviewed the results of emission and capacity testing conducted 

by WEPCO on Port Washington units'" 1-4, submitted on December 22, 1988, 

December 6, 1988, December 23, 1988, and December 23, 1988, 

respectively. Following is a summary by unit of the deficiencies of 

the tests in meeting test protocol requirements: 

Unit 1: 

1. Failure to adequately demonstrate compliance with the Wisconsin 

SIP particulate emission limitation: 

There was significant inconsistency between the particulate test 

results, with the runs ranging between .087 1±>/1VMBTU and .267 

lb/MMBTU. Three of the five test runs were above the allowable 

limitation (.15UVNMBTU). Although WEPCO contends that the first 

two runs were high due to turbine/governor control proJiJ.ems 

resulting in short term surges in the coal feed rate, no 

operational data was submitted to verify the extent of resultant 

load swings and whether it was outside the bounds of normal load 

swings on the unit. Therefore, it was determined that all 5 runs 

should be averaged to determine an actual emission rate of .182 

Ib/MyiBTU, in excess of the allowable limitation: 

Particulate emission 

Run # Date rate (lb/WBTU) 

11/18/88 .267 

11/18/88 .264 

11/18/88 .087 

11/19/88 .125 

11/19/88 _.167_ 

.182 

Failure to maintain compliance with the Wisconsin SIP Opacity 

limitation: 

< 

Operation of this unit resulted in several opacity violations 

above the 20% opacity limitation, both during the initial testing 

days, and the 5 day demonstration period. Following is a summary 

of opacity violations observed during the testing program: 

EPA FORM 13204 (REV. 3-76) 
P.3 

m_ 

11/18/88 

11/19/88 

11/20/88 

11/22/88 

11/14/88 

- 2 

Number minutes 

violation 

84 

6 

6 

54 

6 

Maximum 6-minute 

average opacity^ 

58% 

22% 

21% 

39% 

20% 

3. Failure tn maintain steam drum pressure below agreed limit: 

During the 5 day demonstration period the unit exceeded the agreed 

drum steam pressure limitation of 1,3~0 psi for 22 hours. Maximum 

drum steam pressure was 1,323 psi. 

Unit 2: 

Particulate compliance demonstration: 

Although one of the three test runs was above the aJ ' v.

fable 

particulate emission limitation, the average of the •ee runs 

showed compliance: 

Run ft 

l 

2 

_3_ _ 

Avg. 

Date 

11/10/88 

11/10/88 

11/10/88 

Particulate 'fission 

rate (lb/HBTU) 

.087 

.057 

.195 

.113 

2. Failure tn maintain steam drum pressure below agreed limit: 

During the 5 day demonstration period the unit exceeded tl"^ agreed 

drum steam pressure limitation of 1,050 psi for 27 hours. [laximum 

drum steam pressure was 1,055 psi. 

Unit 3: 

Failure tn maintain compliance with the Wisconsin SIP opacii-/ 

limitation: 

Operation of this unit resulted in some opacity violations above 

the 20% opacity limitation, during the initial test day, and the 5 

^day demonstration period. Following is a summary of opacity 

violations observed during the testing program: 
P.4 

3 -

Number minutes Maximum 6-minute 

Date violation_ average opacity 

11/30/88 48 28% 

12/02/88 30 45% 

2. Failure to maintain steam drum pressure below agreed limit: 

During the 5 day demonstration period the unit exceeded the agreed 

drum steam pressure limitation of 1,325 psi for 36 hours. Maximum 

drum steam pressure was 1,331^psi. 

Unit 4:' 

1. Failure to adequately demonstrate compliance with the Wisconsin 

SIP particulate emission limitation: 

There was significant inconsistency between the particulate test 

results, with the 6 test runs ranging between .043 Ib/MMBTU and 

.782 Ib/iyMBTU. Three of the six runs were above the allowable 

limitation (. 15 lb/MMBTU), and a seventh run was aborted due to a 

wire breakage in the precipitator. It should also be noted that 

testing on this unit was delayed due to another wire breakage in 

the precipitator the prior week. Although WEPCO contends that 

runs 1, 2 and 4 were high due to intermittent feedwater control 

problems, causing surges in the coal feed rate, no operational 

data was submitted to verify this, or whether any resultant load 

swings were outside the bounds of normal load swings on the unit. 

Therefore, it was determined that all 6 runs should be averaged to 

determine an actual emission rate of .279 Ib/MMBTU, well in 

excess of the allowable limitation: 

Particulate emission 

Run ft Date rate (UvTVMBTU) 

.347 

.310 

.135 

.782 

.056 

.043 

1 

2 

3 

4 

5 

6 

. 11/28/88 

11/28/88 

11/29/88 

11/29/88 

11/29/88 

11/29/88 

Avg. .279 

2. Failure to maintain compliance with the Wisconsin SIP opacity 

( limitation: 

Operation of this unit resulted in several opacity violations 

above the 20% opacity limitation, both during the initial testing 

days and the 5 day demonstration period. Following is a summary 

of opacity violations observed during the testing program: 
P.5 

- 4 -

Date 

11/28/88 

11/29/88 

11/30/88 

12/01/88 

12/02/88 

12/03/88 

Number minutes 

violation 

132 

36 

42 

6 

6 

18 

Maximum 6-minute 

average opacity 

i

1

. 

54% 

43% 

26% 

40% 

The design rated capacity for units 1-3 is 690,000 Lb.steam/hr 

maximum continuous 24-hour rating, and for unit 4-655,000 

lb.steam/hr maximum continuous 24-hour rating. It is not kno n 

what the maximum 1-hour capacity on these units is, although unit 

3 operated up zo 720,000 Ub.steam/hr, peak 1-hour average, during 

the demonstraticr. period. 

A review of unit operating loads during the testing program showed 

the follovir.-T .anonstrated operating load for the 50-hour 

.demonstrat • - • period: 

Design Capacity Demonstrated Capacity Percentage ot 

Unit (lb.steam/hr) (lb.steam/hr) Design Capacity 

1 690,000 497,000 72% 

2 690,000 694,000 101% 

3 690,000 690,000 100% 

4 655,000 586,000 89% 

Units 2 & 3 demonstrated a capability of operating at design 

capacity, although unit 3 did have some opacity violations at this 

operating load. Data for units 1 & 4 showed that these units are 

not capable of operating at design capacity. However, emissions 

data (particulate and opacity) for units 1 & 4 show that even at 

these derated levels (72% & 89%) these units are not capable of 

niaintaining compliance with applicable Wisconsin SIP regulations. 

cc: Farrell, SSCD 

Stevenson, ESD 

Solomon, NSR 

Foote, OGC 

Djeu, ORC 

< Kee 

Kertcher 

Spyropoulos 

VanMersbergen