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September 9, 1988 Applicability
of Prevention of Significant Deterioration (PSD) and New Source
Performance Standards (NSPS) Requirements to the Wisconsin Electric
Power Company (WEPCO) Port Washington Life Extension Project 4.37
Although not an official applicability
determination, this memo provided the preliminary
opinion, based on the information collected up to
the date of issue, that PSD and NSPS would apply
to a "life extension" project at Port Washington
Power Plant. Each element of PSD applicability
via major modification and NSPS applicability were
discussed in the context of information provided.
This project involves restoring the physical and
operational capabilities of each unit to its
original capacity and extending the useful life of
the units well beyond the planned retirement dates
that would otherwise apply. This work appears to
be non-routine, and, thus, to constitute a
"physical change"; a significant net emissions
increase would occur as a result of the work.
Notebook Entries: 23.29
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