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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

235)11-1-15 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:51:02 AM Sheet 235 of 276 
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State of Wisconsin \ DEPARTMENT I ._<aXWW I IWL.V J 

Carroll D. Besadny, Secretary 

Box 7921 

Madison, Wisconsin 53707 

TELEFAX NO. 608-267-3579 

TDD NO. 608-267-6897 

July 27, 1990 IN REPLY REFER TO: 4560 

Roger Dodds 

Wisconsin Electric & Power Company 

231 W. Michigan Street 

Milwaukee, WI 53201 

Dear Mr. Dodds: 

The Permit Section of the Bureau of Air Management, Department of Natural 

Resources has received and appreciate your comments on the proposed conditions 

for the air pollution permit No. 90-POY-037 dated June 8, 1990 for Wisconsin 

Electric Power Company (WEPCO) Port Washington Power Plant. The following are 

the responses to your comments. 

. SO? Emission Limitations 

We have consulted with U.S. EPA and it is their position that the reduction of 

emission from an emission unit to avoid NSPS must be achieved by continuous 

operation of control equipment. Fuel switching or load reduction to reduce 

emissions in order to avoid NSPS is not acceptable. This position was given by 

USEPA verbally over telephone conference. We shall obtain confirmation in 

writing and forward you a copy of their letter. 

The permit application submitted by WEPCO stated that sorbent injection will 

be used. By requiring S02 reduction using sorbent injection, we are simply 

approving your proposed method of S0: reduction. If WEPCO wants to use other 

S02 control technology, a permit alteration application must be submitted to 

the Department for review. 

. NOT Emission Limitation 

The purpose of establishing a 30-day averaging period for each boiler's NO, 

emissions was to allow for varying levels of NO, emissions during varying unit 

load conditions. We believes that each boiler at the Port Washington Power 

Plant has, can, and will emit NO, at a rate of not more than 0.4 lb/MMBTU when 

the boiler's emissions are averaged over anv 30 days of operation. 

As you know, under the PSD rules, the Department must determine BACT prior Co 

the construction (or modification) of the affected emissions unit. We have 

considered all of the NO, emissions data you have submitted, 

from the KVB results from 1978 forward to the very recent 

data from the capacity testing at the plant. It is 

certainly true that the NO, emissions vary from Port's archfired furnaces, but we believe that we have accommodated 

this circumstance sufficiently by incorporating a 30-day 

averaging time for compliance purposes. 

WISCONSI N 

I . T « ApMU 1 | » • 
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-Roger Dodds 2. 

If the first several months of CEM data confirm that 0.4 lb 

NOj/MMBTU is unrealistic for any of the Port Washington boilers, Wisconsin 

Electric would then have persuasive evidence of a need for the Department to 

alter the permit as it affects that boiler. The Department has no interest in 

maintaining unrealistic permit conditions, so we would (upon a petition from 

WEPCO to do so and strong evidence of the need for a change) modify the permit 

to satisfy the actual needs of the facility. 

While 0.4 lb N0./MMBTU would perhaps be the most stringent PSD NO, emission 

limit on.a pulverized coal boiler in the United States, the arch-fired 

configuration inherently places such furnaces a step or two ahead of other 

types of pulverized coal firing. Thus, it is reasonable to expect that a BACT 

determination which only requires proper boiler combustion practices would 

result in a more stringent emission limitation for arch firing relative to 

other pulverized coal firing configurations. 

. Fugitive Dust 

The typographical error-of the fugitive dust rule citation shall be corrected 

to read NR 415.04(1), Wis. Adm. Code. 

. Metals Emission Limitations 

Beryllium and mercury are pollutants regulated under the PSD program and 

arsenic is regulated under NESHAP. As you understand, a PSD review must cover 

all regulated pollutants. Your company has chosen to use emission netting to 

avoid PSD for the trace metals. In the netting analysis, WEPCO and the 

Department has used various assumptions and sample test data to arrive at the 

conclusion that the net increase of emissions of trace metals will not exceed 

any of the corresponding significance levels. Thus, PSD does not apply to 

these pollutants. However, we must transform these emission conclusions into 

enforceable limitations. Therefore we shall impose limitations for arsenic, 

beryllium and mercury. The estimated emissions of lead and fluorides based on 

the assumptions supplied by WEPCO are below the PSD significant levels and 

thus no emission netting analyses were done for these two pollutants. No 

emission limitation has been set for lead and fluorides. 

We agree that the concentrations of trace metals in coal can vary. We also 

agree that in general the variations are unpredictable and are uncontrollable 

by the user and the coal supplier. However, we do not agree with WEPCO's 

submittal dated June 13, 1990 which proposes to calculate the 1983/1984 trace 

metals emissions based on the maximum of the published data ("Trace Elements 

in Coal: Occurrence and Distribution", EPA-600/7-77-064) of U.S. Eastern Coal. 

Acknowledging the variabilities of coal in natural occurrence and analytical 

precision, we shall propose new limitations for arsenic, beryllium and mercury 

based on the concentration calculated as follows: 

y - (u + s)(l + v) 

where: y is the estimated concentration in ppm 

u is the average concentration in ppm listed in the above reference 

s is the standard deviation listed in the above reference 

v is the coefficient of analytical variability listed in the 

reference "Interlaboratory Variability and Accuracy in Trace 

Element Analysis of Coal" by, Lengyel, J. and Obermiller, E., 

Consolidated Coal Company, October, 1987. 

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..Roger Dodds 3. 

We believe that this calculation procedure will account for the variabilities 

that WEPCO is concerned about. The new limitations will be: 

Arsenic 

Mercury 

Beryllium 

1.84 x IO"4 #/MMBTU 

3.59 x IO"5 #/MMBTU 

8.64 x IO"7 #/MMBTU 

We shall set these limitations as 12-month rolling averages due to the 

unpredictability of coal samples. 

There will be emission testing requirements for arsenic, mercury and 

beryllium. The detection limits for these arsenic, mercury and beryllium are 

about 0.4, 0.11 and 0.08 ug/m3, respectively. (Ref.: "Measurement Methodology 

for Stationary Source Toxic Mecals Emissions", a paper presented at the 82nd 

Annual Meeting of AWMA (formerly known as APCA), June 25-30, 1989 in Anaheim, 

CA by USEPA and Entropy.-Environmentalists, Inc.) The allowable emissions of 

arsenic, mercury and beryllium are about 95, 18 and 0.45 ug/m3, respectively. 

Thus there should be no problem detecting these emissions. We shall use these 

test data to verify the correlations that WEPCO believe are correct and that 

have been used to predict emissions calculated from the concentrations of 

trace metals in coal. 

. Initial Operation 

We shall define "initial operation", in the permit, as the first time a unit 

is put back into commercial operation after renovation. 

. ESP Operation Parameters 

The conditions 9, 10 and 11 will be changed to reflect that the restrictions 

of operating parameters will be imposed only under steady state operations. 

During startup and shutdown, we shall require WEPCO to follow manufacturer's 

operation manual procedures. 

. CO Monitoring 

Since the CO emission limitation is a renovated plant limit, there is no 

problem monitoring CO for each stack once all boilers (namely B21, B22 and 

B23) exhausting to Stack S17 have completed the necessary renovation and the 

150-day shakedown period. However, before all of boilers B21, B22 and B23 have 

completed renovation and shakedown, CO monitoring shall be required for each 

of the renovated boilers B21, B22 and/or B23. WEPCO may choose to have the 

shakedown periods for these three boilers to be concurrent. 

. Monitoring of ESP Operating Parameters 

We shall change condition 17 to read: 

"The permittee shall submit quarterly reports within 30 days following 

the end of each calendar quarter stating the dates and starting and 

ending times of each period of exceedance of the monitoring requirements 

in conditions 9, 10 and 11, and the magnitude of the exceedance." 

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-Roger Dodds 4. 

Condition 18g shall be deleted. 

. Report of Daily Opacity 

We shall remove the requirement to report daily average opacity in condition 

18a. 

. NSPS Requirements 

Condition 20 is written to cover NSPS requirements applicable to N0X emissions 

from Boilers B21 and B24 by reference. Some of the NSPS requirements are 

already covered by various parts of the permit, such as continuous emissions 

monitoring and that as a result of BACT for N0X, NSPS emission limit is met. 

. Fuel Tvpe Restriction 

The fuels listed in the permit condition are those WEPCO have stated in the 

permit application. We have reviewed the application according to the 

specifications provided-by the applicant, WEPCO. Therefore this permit is only 

valid if WEPCO uses the"fuels as specified. 

. Fluorides and Lead Sampling 

The Department has calculated fluorides and lead emissions based on 

information and assumptions that WEPCO believe will predict the accurate 

emission rates. We have concluded that the post-renovated emission rates of 

fluorides and lead are less than the PSD significance levels for these 

pollutants. Thus no emission limits were set for fluorides and lead. The coal 

sampling requirements for fluorides and lead are design to verify WEPCO's 

information and assumptions. 

. Condition 23 Regarding Phased Construction 

Please note that the condition starts with the word "If". 

In addition to the changes mentioned above, we shall change condition 22c to 

read: 

"Submit quarterly reports within 30 days following the end of each 

calendar quarter which include the contents of lead, beryllium, arsenic, 

total fluorides and mercury in the coal burn for each month during the 

calendar quarter. If the lead content in coal obtained from the same mine 

is below 9 ppm (based on 12-month rolling average) for 24 consecutive 

months, the testing of lead in coal samples from that mine may be 

discontinued. If the content of total fluorides in coal obtained from the 

same mine is below 4.6 ppm (based on 12-month rolling average) for 24 

consecutive months, the testing of total fluorides in coal samples from 

that mine may be discontinued. Each time when coal from a different mine 

is used, testing of lead and total fluorides in coal shall resume." 

We believe monthly sampling of trace metals in coal will be required to 

demonstrate 12-month rolling average emission limit. 
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-Roger Dodds 

If you have any questions to our response to your comments, please bring them 

to our meeting on August 6, 1990 in GEF 2, Madison. 

Sincerely, 

lc*A^i_ X^u^-p/ 

Paul Yeung, P.E. Allen JVHubbard, P.E. 

Permit Section Permit Section 

Bureau of Air Management Bureau of Air Management 

cc: Southeast District 

Dale Ziege, AM/3 

USEPA, Region V 

Mark Steinberg, WEPCO (via facsimile transmission) 

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S <»ee 26 7 337 9 id 1S DNR 

RFCQVP 

State of Fisconsin \ PUBLIC SlRVICt COMMISSION 

CHARLES H. THOMPSON, CHAIRMAN 

MARY LOU MUMTS, COMMISSION!* 

GEORGE R. EDOAR, COMMISSIONER 

480J SKfbevgm Avanut 

P. 0. Bex 78SA 

Mrtiaion. W<«een«jr 83707 

Mr. Carroll D. Besadny, Secretary File No. 6630-CE-133 

Wisconsin Department of Natural Resources 

P.O. Box 7921 

Madison, WI 53707 

! Dear Mr. Besadny: 

Based on a preliminary review, EPA raised concerns about the 

potential applicability of certain air quality regulations to 

Wisconsin Electric Power Company's proposed renovation maintenance 

project at its Port Washington plant. 

Following a number of meetings between your staff and the 

commission staff, this response provides the commission's position 

with respect to the Port Washington projects. The commission 

recognizes that the questions raised by your staff regarding major 

modifications, routine maintenance, repair or replacement are 

questions on which we have expertise that may be of use to DNR. 

However, the commission cannot substitute its judgment for DNR as 

to the definition of these terms under the Clean Air Act. 

"Routine" is subjective in nature, without information on how DNR 

or EPA has applied the definition of "routine" in their clean air 

regulations, it is appropriate for the commission to describe 

the nature of the proposed projects rather than to attempt to 

conclude whether the projects are "routine" in this context. 

In P6C File 5-9300.26, staff has been monitoring power plant 

performance in detail at WEPCO since August of 1979. Discussions 

between WBPCO and staff led staff to conclude that a comprehensive 

approach should be taken regarding plant availability and 

reliability, Staff was encouraged by WEPCO's use of a Plant 

Availability study (PAS) in 1983 to determine a program for 

increasing plant availability. Those recommendations are the 

basis for the Port Washington Projects, The improvement in 

availability and reliability is the goal of these projects. As a 

result of improving the plant's performance, the expeoted life of 

the unit will be changed to 2010. This is an outcome of cost 

effective improvements to plant availability. Maintaining a plant 

in good condition to insure the adequacy of its performance and 

reliability is a normal way for a utility to operate. We should 

point out that maintenance represents a continuum of activities, 

ana includes uuu t m are performed daily, iwfcly, m[[\h 

•annually, every five yeara, once a decade, or even once during the 

life of the plant, ' 
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r 'd -33:00 L3/S\/vQ , '09 I HO 9'93a dd3 WOd2 -»ee 26? 35?9 WIS DNR 93 

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The projects involve the repair and replacement of equipment that 

is worn out or has become obsolete. This includes the data 

acquisition system for the controlB and monitoring of the power 

plant, the water treatment system, the steam turbine blading and 

auxiliary electric systems work. Additionally, the testing and 

inspection of steam piping, chimney liners, and the condition of 

equipment outside of the boiler itself is done regularly. 

inspections and determination for replacement or repair are made 

on a regular basis at all power plants. The fact that the overall 

application to the commission contains numerous projects at a 

significant cost is consistent with the commission's Advance 

Plan 4 process and previous commission action regarding 

improvements in plant reliability. 

in Advance Plan 4f the commission strongly supported the concept 

of the utilities implementing life extension development programs, 

as part of the least cost planning process, balancing environmental 

with economic and other considerations. The commission required 

the utilities to submit programs for review of cost effectiveness 

in order that the negative environmental impact from the siting 

and construction of new generating capacity could be deferred. 

Wisconsin Electric responded by packaging tho results of the PAS 

ln such a fashion as to provide a 4-year consolidated project with 

many different aspects. If this package were to be done on a 

normal scheduled outage basis, most, if not all, of the individual 

projects would probably not even require commission review. TheBe 

projects would be done in a normal timely fashion as needed during 

regular scheduled maintenance. These individual projects are 

neither unusual nor do they involve modifications to the operation 

of the power plant. The packaging of maintenance projects into a 

life extension program should not be dispositive of their 

classification or treatment under clean air regulations. 

A project that involves the boiler specifically is replacement of 

the rear steam drums on Units 2,2,4 and 5. Replacement of the 

steam drums is needed for safe, reliable operation of the units. 

The determination that they needed to be replaced was found during 

inspection of one of the units. Replacement of worn, unreliable, 

unsafe components is not unusual at power plants and such single 

components can require a great deal of construction and labor to 

repair or replace. The steam drums fall into that category. It 

should be noted that the steam drum on Unit 1 is in satisfactory 

condition and is older than the others. It has not had to be 

replaced and it is expected to continue to give useful J.ife until 

the year 2010, The commission does not consider drum replacement 

to be any modification to the boilers. The design of the power 

plants will remain the same. 
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•nn 'P/PI/fr O TiciIH3 g'9 ^ Hd3 ',10ad 

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The precipitator modifications are a replacement of obsolete 

electric controls on the existing precipitators. The 

precipitators themselves will not be modified in the way they 

operate. The old controls cannot be replaced because they are no 

longer being made. New controls are necessary to provide more 

reliable precipitator operation. These types of projects are 

normal and done on a regular basis at other Wisconsin power 

plants. 

In the commission's opinion, none of the projects proposed,' 

whether they be for facilities outside or inside the boiler, will 

modify the design of the power plant. WEPCO views the proposed 

work as necessary to maintain the usefulness of this plant's 

generating capacity in its intended function as originally 

designed and operated. 

There is an underlying issue raised by life extension programs, 

that is the impact on air quality. The commission believes this 

is a policy question that should be addressed directly rather than 

by defining the nature of the projects to achieve a desired 

outcome. The commission intends to address this issue in upcoming 

proceedings and would invite your comments and participation. 

The commission is providing this information based on previous 

commission review and on its experience in working with utilities 

and utility power plants. The commission hopes that the 

information provided will be helpful to DNR in making this and 

other reviews. 

The commission appreciates the opportunity to provide assistance 

to the DNR and is prepared to work further or provide additional 

information, if requested. 

By the Commission, 

Signed )7&- day of _. fi |ggci.t^ 19?% 

Jr'ae^eAn •WueZYneXTReynolds e x7 Reyno; ' 

Secretary to the Commission 

JKR.RSC:DMD;rab02298802 

ect Mr. Donald P. Theiler, DNR 

Mr. Steve Rothblatt, EPA 

See attached Notice of Appeal Rights.