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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

225) 11-1-5 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:51:02 AM Sheet 225 of 276 
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PUBLIC SERVICE COMMISSION C 

DSPA&TMENTAl CORRESPONDENCE 

II-I-5 

Fil e No. 6630-CE-133 

March 7 , 1988 

FOR COMMISSION CALENDAR 

TO: The Commission 

FROxM: R. S. Cullen, Administrator 

Engineering Division 

ft£ 

D. M. Dasho, Staff Engineerr>/£? 

Engineering Division j*^** ^ 

SUBJECT: Application of Wisconsin Electric Power 

Company for Authority to Perform Major 

Renovation Maintenance on Port Washington 

Units 1 Through 5 and Common Facilities, 

All at Its Port Washington Power Plant 

Located in the City of Port Washington, 

Ozaukee County 

Letter to Department of Natural Resources 

Suggested Minute: The commission approved a letter to the 

Department of Natural Resources concerning Wisconsin 

Electric Power Company's Port Washington application. 

On July 13, 1987, the Wisconsin Electric Power Company 

(WEPCO) filed an application for authority to perform major 

renovation maintenanca on Port Washington Units 1 through 5 and 

the associated common facilities at its Port Washington Power 

Plant (PWPP). 

An issue has come up concerning the proposed renovations 

at FWFP as it concerns both the Department of Natural Resources 

(DNR) and the United States Environmental Protection Agency (EPA). 

MAR 1 6 1988 

Air & Radiation Branch 

U.S. EPA Region V 
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The question was raised by a DNR letter dated November 9, 1987, 

(Attachment A) to the EPA requesting certain clarifications 

regarding the proposed project. Specifically, how the provisions 

of Prevention of Significant Deterioration (PSD) regulations would 

apply to the proposed renovations. Recently, on November 4, 1987, 

the EPA made an agreement with the DNR concerning the delegation 

of authority to implement a PSD program. The delegation by EPA to 

DNR states that "permits issued under this delegation are required 

to contain language stating that the PSD permit is issued after 

determining that federal PSD requirements have been satisfied," 

The Wisconsin DNR has been delegated the authority to make 

determinations on PSD regulation in the state. 

DNR's letter to EPA stated "the State of Wisconsin will 

not view the renovations at the Port Washington plant to actually 

modify any of the boilers." EPA's response on December 23, 1987 

to DNR (Attachment B) stated that the renovations could be subject 

to PSD regulations. On February 4, 1988 (Attachment C), the DNR 

sent a follow up letter to EPA in which it stated again 

"it is the opinion of DNR that renovations at 

WEPCO-Port Washington are similar to those at 

Bekjord and are indeed routine in nature for a 

utility. Therefore, like at Bekjord, a PSD 

permit is not required of WEPCO for the undertaking of the proposed plant life extension 

activities." DNR goes on to ask, "What is your 

view of our interpretation of the applicability 

of the PSD regulations to the WEPCO-Port Washington 

renovations? We believe that you will agree that 

WEPCO may proceed with this life extension project 

without a PSD permit." 

The issue at hand is whether or not the EPA will agree 

with DNR as regards a PSD permit. The importance of a PSD permit 

is that its emissions control requirements are very strict. WEPCO 

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S00 NOv particulate, etc. These standards may prove to be more 

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strict than the current New Source Performance Standards (NSPS) 

that are required of new generating units. The cost of providing 

this additional pollution control equipment would in all likelihood 

stop the renovation projects from proceeding. Without the renovation 

work at the PWPP, 160 MW of capacity will be lost permanently. 

The entire Advance Plan 5 submitted by WEPCO and the 

Eastern Wisconsin Utilities (EWU) would have to be reconsidered if 

this capacity was not available as assumed in the planning 

process. The PWPP is important not only to WEPCO but to all of 

EWU both for generation and transmission support. 

It should be pointed out that the regulations allow 

emissions to double without any restrictions if the units were 

just operated more hours. 

In its February 5 letter to the EPA, the DNR stated "A 

letter summarizing PSC's facts on the Port Washington project and 

how it fits in with Wisconsin's Utility Advance Plans is in 

process." In meetings between DNR staff and commission staff in 

January, staff proposed sending a letter to DNR with the 

commission's comments on this issue. As DNR points out in its 

letter, it has limited experience in utility boiler maintenance 

and has discussed these issues with staff requesting our assistance 

in evaluating the planned maintenance activities. Engineering 

Division has concurred with DNR's opinion regarding the maintenance 

at Port Washington. 
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Engineering staff views the maintenance proposed for 

Port Washington as consistent with the requirements not only in 

Advance Plan 4 but also the direction and directives that have 

been given to WEPCO over the years regarding its power plants. 

The Advance Plan 4 order provisions 37, 38 and 39 specifically 

addressed life extension and required the utilities to implement a 

generating plant life extension program from a least cost planning 

perspective. The point of these provisions was that the detrimental 

environmental impacts of new generating capacity additions could 

be eliminated, diminished or deferred. The provisions go on to 

state that the commission needs to review the plans for generating 

plant assessments and evaluations to ensure the plans will adequately, 

thoroughly and consistently assess and evaluate the costs and 

benefits. All utilities have submitted or will submit plans to 

the commission. These AP-4 provisions are clear in their intent. 

in PSC File 5-9300,26 staff has been monitoring power 

plant performance in detail at WEPCO since August of 1979. 

Discussions between WEPCO and staff lead staff to conclude that a 

comprehensive approach should be taken as regards 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, not 

plant or system modification. As a result of improving the plant's 

performance the expected life of the unit will be extended to 2010, 

This is a secondary outcome of cost effective improvements to 
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plant availability and not the goal of the projects. Maintaining 

a plant in good condition, insuring its performance and 

reliability are adequate, is a proper, normal and routine way for 

a utility to operate. 

Maintenance projects of this nature are routinely dealt 

with by the commission. The Accounts and Finance Division 

classifies maintenance and capital projects at power plants every 

year. Most maintenance is expensed and some is capitalized. If 

A&F can't determine whether it should be capitalized or expensed 

they request Engineering to advise them and follow our 

recommendations. 

The PWPP Project 

PWPP is made up of 5 units of similar design 80 MW each. 

Each unit uses the traditional WEPCO arch-fired boiler designed 

for base load operation. This original design of the PWPP has 

made it one of the lowest producers of nitrogen oxides (NOX) in 

the country. The subsequent addition of generating units at Oak 

Creek, Pleasant Prairie, Valley and Point Beach has meant that the 

PWPP has been operated less as base load and more as cycling 

capacity in recent years. The increased cycling of the plant 

causes more wear and tear due to increased thermal cycling of 

major components. Today's increased cycling operations require 

improved monitoring and control to provide for more efficient unit 

operation. 

In addition to changing operational requirements, the 

PWPP is between 37 and 52 years old. Equipment has worn out, 

oricinal technology had become obsolete and plant availability has 
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declined. To improve operational efficiencies, reduce costs and 

maintain reliable service to its customers, WEPCO has proposed, to 

undertake a comprehensive plant renovation maintenance program at 

PWPP. 

There are 51 separate projects proposed by WEPCO for 

PWPP. The renovation work includes both unit-specific projects 

and projects common to all 5 units. There are 6 similar projects 

that involve each of the 5 separate units accounting for 30 of the 

51 projects. 

Included in these are major rework of the steam turbine 

spindle, blading, and cylinder cracks, as necessary. In addition 

the main steam and reheat piping will be inspected and replaced, 

as necessary, on all 5 units. 

Another project involving all 5 units will be the 

replacing of existing coal pulverizer mill ducts outlet piping 

with upgraded materials. The ducts are the pathway by which the 

pulverized coal from the mills is injected into the boilers. Over 

a period of years, erosion and corrosion has caused perforations 

and leakage in these ducts. 

Because of their age, the units lack the up-to-date 

monitoring and control systems necessary for today's demanding 

operation. An example of this is the present carbon monoxide and 

oxygen (CO/02) monitoring system installed in the boilers. While 

adequate when originally installed, present monitoring 

deficiencies result in less boiler efficiency, higher fuel use, 

increased fan power requirements and fire hazards in the fly ash 

hoppers due to unburned carbon in the ash. A new CO/02 monitoring 

system including 4 to 5 new oxygen analyzers per unit would be 
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installed. The data will be displayed to the operators through 

the data acquisition system. This will enhance the operators 

ability to operate the units more efficiently and reduce the 

amount of excess air required. 

Other aspects of the existing data acquisition system 

are obsolete. The basic problems with this system are maintenance 

problems due to unavailability of hardware and parts, and software 

limitations. Due to its age, no company has the skill to maintain 

the hardware and software of this system. No backup exists for 

the remote terminal units and no performance measurement and 

monitoring of the boiler/turbine were incorporated into the 

system. 

The plant renovation calls for the replacement of the 

existing data acquisition system with a modern Distributed Control 

System (DCS). The DCS will incorporate the latest design features 

such as distributed architecture for the data acquisition task. 

This system will significantly improve the efficiency, safety and 

reliability of plant operations. Installation of these systems 

should be encouraged at all older units. 

The renovation also includes improving the plant's water 

chemistry with the installation of new boiler chemistry and 

monitoring system. The current system of manual chemical addition 

and monitoring produces unreliable results with frequent 

exceedances of water chemistry parameters for the boilers. 

Improved water chemistry will improve boiler and unit performance. 

The two chimneys that serve the 5 units will have to be 

renovated. Deterioration of reenforced concrete liners has 

occurred due to acid attack and silicate thermal stresses. 
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Inspection reports by WEPCO revealed cracking and spalling of the 

liners. Life expectancy of the liners in their current condition 

may be less than 5 years. 

Additional common items to be worked on, replaced or 

added during the renovation include upgrading the computer room 

HVAC system, installing a new computer room and adding a fire 

detection system in the electrical switches located immediately 

adjacent to the turbine floor. This work is needed to bring these 

facilities up to current standards. The electrical system is to 

be upgraded and is required because spare parts for the system are 

no longer available. 

From the above description these are the kinds of 

projects that are done on a routine basis at power plants as 

needed. There is nothing unique nor unusual in upgrading obsolete 

or worn out components at a power plant. The reason that the 

projects have come before the commission is that the commission 

required WEPCO to lump these projects together and bring them as a 

group to the commission. These projects in all likelihood, had it 

not been for Advance Plan 4, would have been done on a piecemeal 

basis as unit outages were taking place. The determination of 

whether or not these projects should be done would be based 

strictly on economic criteria. If the maintenance cost of a piece 

of equipment or system exceed the cost of replacing it with a 

newer piece of equipment, the replacement would be done. This is 

ordinary maintenance analysis. 

None of this work will modify the operation of these 

units. The work will improve the safety, reliability and 
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efficiency of unit operation. This type of work goes on at power 

plants on a regular basis. 

As far as the work on the boilers is concerned, only the 

rear steam drums on Units 2, 3., 4 and 5 will be replaced and the 

precipitators controls will be modified. The rear steam drums 

have been *.;ound to have cracks in them that require immediate 

attention. A determination that there is a problem in a unit and 

a component needs to be replaced is something that is done on a 

regular basis. Equipment is constantly being inspected to 

determine if it is reliable and safe. While the amount of 

construction work for replacing the rear steam drums may be large, 

the cost of doing so is small in comparison to the replacement 

cost of the boiler. Replacing the rear steam drum will not impact 

on the gas stream leaving the boiler. It will not impact the 

quantity or type of emissions. 

The precipitator modifications include upgrading the 

electrical controls on the existing precipitators. These controls 

are old and obsolete and can no longer be repaired or replaced. 

They need to be upgraded with new controls. This is not an 

increase or change in the operation of the precipitators; merely 

an upgrading of the controls. 

Engineering staff has reviewed this and the other 

projects in detail. This review has pointed up no areas where 

there would be unusual or unexpected projects taking place. At a 

power plant, maintenance and capital projects are required on a 

regular basis to maintain the operation of the plant. Included in 

Attachment D is a letter from WEPCO providing more detail on the 

types of projects that are proposed. 
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WEPCO also makes a good case on the point of whether or 

not these projects are extending the life of the units. If you 

look at it from an accounting basis and assume that the plants had 

a 35 year life, then all the units have already had life 

extension. Yet no specific "life extension" projects have been 

done in the past; merely the kinds of work that keep the units 

operating in a reliable fashion. 

For system planning purposes, a set date is used for the 

retirement of a power plant. However, as you approach that 

planning date, as we are with the PWPP, it becomes clear that, 

with regular cost-effective maintenance projects maintaining the 

units in a reliable condition, the retirement dates could be 

extended further into the planning horizon. This does not mean 

that the projects being done are life extension projects as such 

but the end result is that the planning horizon may change. The 

planning horizon is only that; a planning horizon. It is not a 

physical assessment of when the plant will reach the end of its 

life. It is merely a device to use for long-term looks into the 

future. These dates are then revised as necessary when a new 

planning cycle is done. 

The Engineering Division recommends that the commission 

send a letter to DNR that would include these comments in support 

of the position that these projects involve routine repairs and 

replacements to accomplish the proposed renovation maintenance at 

PWPP. There is nothing unusual or different in the approach that 

WEPCO is using in assessing the maintenance requirements for this 

power plant. 
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The projects taken as a whole will not change the 

operation of the power plant. They will not modify the way coal 

is burned; they will not modify the way the gas stream is treated; 

they will not modify in any sense the design of these units. This 

is not a modification, this is renovation maintenance. This 

should be stated clearly to the DNR. 

In taking this position, we are making an engineering 

determination here at the commission on how we view these projects 

from a Public Service Commission standpoint. It is up to DNR and 

EPA to make their own determination on the applicability of their 

air quality regulations. Whatever the DNR and the EPA decide in 

this matter is what we will have to work with. 

Finally, if the commission chooses not to take a 

position on this issue both DNR and the utility will have to 

proceed without our input. It should be pointed out that if this 

project is not viewed as routine it will in all likelihood put an 

end to integrated comprehensive maintenance activities at older 

utility plants and industry boilers, viewing broad scale 

maintenance activities as major modifications will eliminate any 

desire on the part of utilities to modernize older plants. This 

would be a result to no one's benefit. 

We recommend the attached letter be sent to DNR, in 

response to its request on this matter. 

RSC:DMD:reb02298801 

cc: Don Theiler, DNR 

Allen Hubbard, DNR