UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 5 

77 WEST JACKSO N BOULEVAR D 

CHICAGO, IL 60604-3590 

NOV 2 1 2012 

REPL Y TO TH E ATTENTION OF: 

Andrew Stewart 

Chief 

Permits and Stationary Source Modeling Section 

Bureau of Air Management 

Wisconsin Department of Natural Resources 

PO Box 7921 

Madison, Wisconsin 53707-7921 

Dear Mr. Stewart: 

The U.S. Environmental Protection Agency has the following comments on the Wisconsin 

Department of Natural Resources' (WDNR) draft of the Prevention of Significant Deterioration 

(PSD) and major source nonattainment new source review (NNSR) permit for the WE Energies 

Elm Road Generating Station. The draft permit is being proposed as a construction permit (#12-

SDD-047). The facility operates two coal fired boilers with a combined output of 615 MW. The 

boilers were previously permitted to burn only bituminous coal. The draft permit would 

authorize the facility to burn subbituminous coal, either in combination with bituminous coal or 

as the sole type of coal combusted in the boilers. It also would authorize physical changes 

necessary to burn the two types of coal fuel. The WE Energies Elm Road Generating Station is 

an existing major source under the NNSR program for Particulate Matter of less than 2.5 

micrometers and is a major source under the PSD program. The project is a major modification 

under PSD for several pollutants, including greenhouse gases (GHGs). 

In order to ensure that the project meets Clean Air Act requirements, that the permit will provide 

necessary information so that the basis for the permit decision is transparent and readily 

accessible to the public, and that the permit record provides adequate support for the decision, 

EPA has the following comments. 

1) Page 23 of the Preliminary Determination document indicates that that facility was 

allowed to use a different time period than the 24-month period because... "the units are 

new (operating only since October 2009 for unit 1 and July 2010 for unit 2) and they did 

not operate at a representative rate during the first few months to the first year of 

operation. The applicant has proposed the period of October 2010-September 2011." 

WDNR granted this request since the units were "not operating normally due to the need 

for startup and shakedown work." However, the baseline period used to calculate the 

Best Available Control Technology (BACT) limit for Carbon Monoxide (CO) was from 

December 2009 until December 2011, which includes the time period that WDNR 

determined is not representative of normal operation for other pollutants in the netting 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post-Consumer) 
analysis. Please explain why this time period is representative for CO and not 

representative for other pollutants, or make the necessary changes to your analyses to 

correct this discrepancy.. 

2) Page 19 of the Preliminary Determination document states that an air quality analysis is 

not required because "[a]U potential emissions for the emissions units covered in the draft 

permit are either the same or lower than the emissions rates which were modeled in 

previous construction permit for this facility." It seems that the construction permit 

referenced is permit #03-RV-166-R5, which was issued in October 2009, Under NR 

405.09 the source must show that its allowable emissions and all other applicable 

emissions increases and decreases will not cause or contribute to a violation of National 

Ambient Air Quality Standards or increment. "All other applicable emissions" include an 

up-to-date inventory of emissions in the area of concern that were not included in the 

original modeling analysis. Additionally, since certain modeling requirements have 

changed since 2009, WDNR should ensure that the permit for this major modification 

adequately reflects all of the new requirements. For example, since this modification will 

have a significant emissions increase in Volatile Organic Compounds (VOC) and 

Nitrogen Oxides (NOx) it should conduct an ozone impacts analysis. Please complete an 

ozone impact analysis and update the previous modeling to include the latest 

meteorological data, emissions data, and any new models required since the 2009 

modeling (such as 1-hr nitrogen dioxide and sulfur dioxide) or provide justification that 

no changes to the above have occurred since the previous modeling. 

3) 173(a)(3) of the Clean Air Act states that the permit program required by 172(b)(6) shall 

provide that a permit may be issued if... "the owner or operator of the proposed new or 

modified source has demonstrated that all major stationary sources owned or operated by 

such person...in such state are subject to emission limitations and are in compliance, or on 

a schedule for compliance...". At this time the Paris Generating Station in Kenosha, 

which is also operated by WE Energies, is not in compliance and a compliance schedule 

has not yet been finalized. The Paris Generating Station is not in compliance because of 

modifications done in 2000-2002 to replace turbine blades. The modifications were 

determined, after the fact, to be major modifications and may have triggered PSD review. 

A draft permit incorporating the compliance schedule for the Paris Generating Station 

(#230094810-P02) was public noticed on October 5, 2012 and has not yet been issued. 

Until the compliance schedule is finalized, the permit for WE Energies Elm Road 

Generating Station (#12-SDD-047) may not be issued. 

4) Page 13 of the Preliminary Determination document states that the GHG BACT analysis 

will include CO2, methane, and nitrous oxide, but there is only a proposed GHG BACT 

emission limit for CO2 and not for methane or nitrous oxide. Since the regulated NSR 

pollutant is defined as GHG, the GHG emission limit(s) should account for not only CO2, 

but for all of the GHGs that are emitted. Please also clarify how compliance will be 

demonstrated for the each of the GHGs. 

5) Page 14 of the Preliminary Determination document states that building a CO2 pipeline 

would cost millions of dollars to construct and concludes that carbon capture and 

2 
sequestration (CCS) is economically infeasible for controlling GHGs for this project. In 

order to support this conclusion, please include in the permit record your CCS cost 

analysis (e.g., an annualized cost per ton of CO2 removed, or a capital cost comparison to 

the total cost of the project) along with the rationale for why the costs are economically 

infeasible. 

6) The permit contains a Lowest Available Emission Rate (LAER) emission limit for VOC, 

however the preliminary determination does not address how the LAER limit was 

selected. Please include the analysis used in preparing the LAER determination in the 

permit record. 

7) Please correct the typographical error in condition LA. 15.b.(3). Current language reads, 

"The permittee shall perform the compliance emission tests required under condition 

I.A.15.b.(l) every 60 within 60 days of the anniversary date of the initial test as long as 

the permit remains valid." It appears that a unit of time is missing. If appropriate, please 

change the language to. "... every 60 months within 60 days of the...". 

8) It appears that permit condition I.A.2.c.(7) is repeated in I.A.2.c.(l 1). If appropriate, 

remove condition I.A.2.c.(l 1) to avoid repetition. 

9) It appears that two permit conditions were both labeled I.A.2.b.(5). If appropriate, please 

change the label of the condition on page 7 to I.A.2.b.(6) to improve clarity. 

We look forward to working with you to address all of our comments. If you have any further 

questions, please feel tree to contact Andrea Morgan, of my staff, at (312) 353-6058. 

Sincerely, 

Genevieve Damico 

Chief 

Air Permits Section 

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