Due to an issue with the Wisconsin Department of Natural Resources (WDNR), Wisconsin Electric Power has had to shut its Paris Generating Station Units 1 and 4 peakers until it can get a permit for a long-ago upgrade project.
Between 2000 and 2002, the utility replaced the blades on the four Paris Generating Station (PSGS) combustion turbine generators with blades that were about 7% more efficient. Although the work was performed as routine maintenance that Wisconsin Energy did not believe required a construction permit at the time and the plant has not been operated to use the potential additional capacity, the WDNR has indicated that it now considers this maintenance to be a modification requiring a construction permit, said Wisconsin Electric parent Wisconsin Energy in its Aug. 1 Form 10-Q filing.
The WDNR issued a Notice of Violation (NOV) to Wisconsin Electric on Jan. 7, 2013, alleging violations of the new source review rules and certain Wisconsin environmental rules. The WDNR also issued an administrative order that prohibits the utility from operating PSGS Units 1 and 4 until the earlier of: Units 1 and 4 achieve the applicable NOx emission rates; the Wisconsin regulations are revised so that Units 1-4 can achieve the emission limits or are no longer subject to the limits; the alleged modification is resolved through a consent decree; or until a court decides that the blade replacement project was not a major modification.
“We are presently evaluating alternative approaches to return these peaking units to service, and expect that Units 1 and 4 will remain out of service until at least 2014,” said the company in the Form 10-Q. “In addition, we may be subject to fines and penalties. In February 2013, the Sierra Club filed for a contested case hearing with the WDNR in connection with the administrative order. The WDNR has granted that petition, but a hearing has not yet been scheduled. In addition, in May 2013, the WDNR referred the matter to the Wisconsin Department of Justice (DOJ) for alleged violations of air management statutes and rules.”
Wisconsin Electric evaluated the impact that this outage may have on network reliability, and concluded that it will not need to find alternative sources of generation in the short-term to replace this generation from these units. PSGS Units 2 and 3 remain available for operation because the turbine blade maintenance on these units occurred prior to a rule change in 2001.
Each of the four gas-fired (diesel fuel as a backup) Paris units has 100 MW of capacity.
Said an April 8 permit application filed by Wisconsin Electric with the WDNR: “This air pollution construction permit application requests authorization for two separate, unrelated projects at the Paris Generating Station. The first project involves equipment replacement work that occurred in 2000 to 2002. The work was the routine replacement of the Unit 2 and 3 combustion turbine blades. At the time the project was conducted, We Energies concluded that this project was not subject to New Source Review (NSR) or New Source Performance Standard (NSPS) permitting requirements. After the project was completed, U.S. EPA was asked to provide a NSR applicability determination regarding the project. The agency ultimately did not do so. After discussing the Paris project with Department staff, We Energies agreed to submit an ‘after-the-fact’ construction permit application for the project. In doing so, We Energies is not agreeing or admitting that the applicable laws and rules in effect in 2000-2002 required a construction air permit for this project.”
The application added: “The second project is the installation of two new diesel fuel-fired emergency electric generators. The two projects are economically and technically independent. The time between the projects is more than 10 years. Thus, these projects have not been aggregated for NSR applicability.”
The Paris Generating Station is located in Union Grove, Kenosha County, and consists of four simple-cycle ASEA Brown-Boveri (ABB) Model 11N combustion turbine-generators which fire natural gas as the primary fuel, and low sulfur diesel fuel as an emergency backup fuel. Units 1 and 2 were placed in service in 1993 and Units 3 and 4 were placed in service in 1994. In 1999, an inlet cooling system was added to increase the summer peaking capability of the units.