Draft Notes from Site Visit at 

We Energies’ Pleasant Prairie Power Plant 

on March 2, 2010 

 EPA conducted a site visit at We Energies’ Pleasant Prairie Power Plant (Pleasant 

Prairie) located in Pleasant Prairie, WI on Tuesday, March 2, 2010 to learn about the operations 

at the plant, specifically the flue gas desulfurization (FGD) wastewater treatment system. These 

notes describe the information collected during the site visit. Table 1, located at the end of these 

notes, identifies the site visit participants. An FGD wastewater flow diagram and an overall plant 

water balance diagram are provided as Attachments 1 and 2, respectively, to these notes. 

Plant Overview 

 Pleasant Prairie operates two coal-fired generating units at the power plant. Units 

1 and 2, which began operation in 1980 and 1985, respectively, each have a 

capacity of 615 megawatts (MW). Both units are operated as baseload units. 

 Pleasant Prairie retrofitted Units 1 and 2 with FGD scrubber systems to control 

the sulfur dioxide (SO2) releases from the plant. The FGD scrubber systems were 

installed in November 2006 (Unit 1) and March 2007 (Unit 2). With the addition 

of the FGD scrubber systems, Pleasant Prairie also installed an FGD wastewater 

treatment plant to control the discharges of the wastewater generated during the 

operation of the FGD scrubbers. 

 SCR systems were retrofit additions to the plant and were installed on Unit 2 in 

2003 and Unit 1 in 2006. [QUESTION FOR PLEASANT PRAIRIE: Did the 

plant install the FGD scrubber system and SCR system on Unit 1 at the same 

time?] SCRs are used to control nitrogen oxide (NOx) emissions. The plant 

operates the SCR systems year round. 

 Pleasant Prairie operates cold side electrostatic precipitators (ESPs) on both Units 

1 and 2. The ESPs remove approximately 99.7 percent of the particulates in the 

flue gas. Pleasant Prairie operates a dry fly ash handling system. 

Pleasant Prairie recently installed a calcium bromide injection system for the boiler. A 

liquid form of 50% calcium bromide is sprayed on to the coal at the inlet to the 

ball mills used to pulverize the coal. The bromide addition results in conditions 

that lead to the oxidation of mercury into a form that increases its removal in the 

wet FGD system. The bromide injection system has been achieving 60-70 

percent mercury removal, or better. Mercury is ultimately removed from the wet 

FGD blowdown at the treatment facility and the dried wastewater sludge is landfilled. Increased amounts of flue gas mercury removal (adsorbed to the fly ash) in 

the precipitators has also been observed. The system injects a solution of calcium 

bromide into the boiler which enhances the oxidation of mercury in the flue gas. 

The oxidized mercury is more easily removed in the FGD scrubber system and,

therefore, lowers the plant’s mercury emissions. 

Comment [dml1]: Yes. The SCR and FGD 

systems for U1 installed and placed into service at 

the same time. 


 Pleasant Prairie burns Powder River Basin (PRB) coal in both units. The plant 

burns approximately 5.5 million tons of coal per year. 

 Pleasant Prairie is located about 5 miles away from Lake Michigan. The plant 

discharges to Lake Michigan.

 During the site visit, Unit 1 was in a scheduled maintenance outage. During this 

outage, the air heater baskets were serviced and the annual boiler work was 

completed. 

Carbon Capture Study 

 Pleasant Prairie participated in a pilot-scale carbon capture technology study in 

collaboration with EPRI and Alstom that started in 2007 and ended in October 

2009. The study used a slip stream of the Unit 1 flue gas from either P4 Unit 2 or 

P4 Unit 1 to test Alstom’s chilled ammonia carbon capture technology. Alstom 

and EPRI operated the pilot-scale system at the plant for approximately two years 

before the study was completed. [QUESTION FOR PLEASANT PRAIRIE: 

From which unit was the slip stream taken and treated?] The carbon capture pilot 

was set up to obtain flue gas from P4 Unit 2. A back up connection was later 

added to allow the carbon capture pilot to remain in service when P4 Unit 2 was 

shut down for its annual scheduled maintenance outage, or was off line due to a 

forced outage. 

 Plant personnel stated that the carbon capture system was successful in removing 

up to 90 percent of the carbon dioxide from the flue gas. Following capture the 

carbon dioxide was routed to the flue gas and emitted to the stack.

 Pleasant Prairie stated that the plant is located over sub solid rock, limiting the 

ability to sequester any captured carbon in the ground; therefore, the carbon 

dioxide captured during the study was transferred off site.[QUESTION FOR 

PLEASANT PRAIRIE: Where and how was the captured carbon transferred offsite?] 

 Plant personnel stated that the lessons learned from the study at Pleasant Prairie 

were incorporated into the pilot study that is taking place at AEP’s Mountaineer 

plant in New Haven, WV. 

 Plant personnel explained that the system at the Pleasant Prairie site utilized 

aqueous ammonia and sulfuric acid for pH adjustment in the absorber. The 

process generated a waste stream consisting of an ammonium sulfate solution. 

The plant’s wastewater treatment system does not treat for ammonia; therefore, 

the wastewater stream from the study was collected and transferred off site. The 

generated non-hazardous wastewater was transferred off-site and treated at 

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Comment [dml2]: This research was to evaluate 

capture, not sequestration. See edit to bullet point 

above. Note – this project did not involve an 

evaluation of the potential to store CO2 below P4, 

nor anywhere else in SE Wis. Therefore, I’d remove 

this bullet point completely. 
Beaver Royal Oil Company in Illinois. [QUESTION FOR PLEASANT 

PRAIRIE: How was the wastewater treated by Beaver Royal Oil and what did 

they do with the wastewater after treatment?] Beaver Oil Company received the 

dilute ammonium sulfate waste stream from Alstom Power's Chilled Ammonia 

Carbon Capture Pilot at We Energies P4, and placed it "into their general waste 

treatment feed." It was mostly water and was used for pH adjustment of incoming 

feeds to allow for precipitation in their batch treatment tanks.

 Pleasant Prairie stated that because the carbon capture system was operated by 

Alstom and EPRI, they were uncertain of the generation rate for the wastewater 

stream. Additionally, Pleasant Prairie does not have any analytical results 

characterizing the waste stream; however, the plant believes that EPRI should 

have characterization data. Pleasant Prairie stated that they do not know if the 

characterization data will be included in the final report prepared for the study. 

[QUESTION FOR PLEASANT PRAIRIE: Please provide the letter that was 

submitted to the DNR that estimated that characteristics of the waste stream.] 

 EPRI collected water and air samples from the system during the study. Plant 

personnel stated that a final report, from EPRI, may be available by the end of 

2010. 

FGD Operation 

 Pleasant Prairie has two identically designed FGD scrubber systems on Units 1 

and 2.

 The FGD spray tower has three spray header levels; however, the plant typically 

only operates two of the spray levels at one time. The FGD scrubber systems are 

also equipped with one dual flow tray. 

 The plant does not add any organic acids to the scrubber (e.g., DBA) because the 

plant’s FGD wastewater treatment system does not have the capability to remove 

the BOD from the system. Pleasant Prairie stated that if they did add organic acids 

they would have to send the wastewater to a POTW for treatment.

 The plant has experienced some problems with foaming in the absorber; therefore, 

they have been adding a silicone-based antifoamant to control this issue. The 

plant adds between 10 and 20 gallons of the antifoamant per day.

 The plant uses a limestone slurry as the sorbent for sulfur dioxide (SO2) 

absorption. The two scrubber systems share two Each unit has its own balls mill 

where the limestone is ground and mixed with water to 40 to 50 percent solids by 

weight. The plant uses hydrocyclones to classify the limestone and ensure the 

correct size particles are used in the FGD scrubber system.

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Comment [dml3]: Copies of our submittal and 

the DNR response are attached. 
 Pleasant Prairie maintains the solids concentration in the FGD scrubber systems 

between 158 and 218 percent solids. When the solids concentration exceeds 18 

percent, the plant blows down from the FGD scrubber. Plant personnel estimated 

that each unit blows down for about 8 to 10 hours each day. The plant tries to 

stagger the blow down from the two units.

 Pleasant Prairie also maintains the chloride concentration in the FGD scrubber 

systems between 3,000 and 10,000 ppm. The plant tries to keep the chlorides 

concentration around 6,000 ppm, or lower. The maximum design chlorides 

concentration is 15,000 ppm.

 Plant staff indicated that the chloride concentration in Unit 1 tends to be higher 

than in Unit 2 because water from Unit 2 is recycled to Unit 1.

 The blowdown for each FGD scrubber system is transferred to its primary 

hydrocyclone. Each FGD scrubber system has a dedicated hydrocyclone. The 

underflow from the primary hydrocyclones, which is 50 percent solids, is 

transferred to the vacuum belt filters where the plant washes the gypsum to lower 

the chlorides concentration in the gypsum. Each primary hydrocyclone feeds 

either of two common a dedicated vacuum belt filters. The vacuum belt filter dries 

the gypsum to less than 10 percent moisture. Pleasant Prairie sells the gypsum to a 

wallboard manufacturing in Waukegan, IL, as well as for agricultural uses. 

 The filtrate from the vacuum belt filters is collected and transferred back to the 

FGD scrubber systems. All the filtrate is typically transferred back to the Unit 1 

FGD scrubber system; however the plant has the capability to also send the 

filtrate to the Unit 2 FGD scrubber system.

 The primary hydrocyclone overflow from the two units are commingled together 

and transferred to a common secondary hydrocyclone. The underflow from the 

secondary hydrocyclone is recycled back to the FGD scrubber systems. The 

overflow from the second hydrocyclone is transferred to the FGD wastewater 

treatment system. 

FGD Wastewater Treatment System 

 The FGD wastewater treatment system is designed to receive intermittent 

discharges of FGD wastewater from the secondary hydrocyclones. Normal system 

flow is at a flow rate of approximately 40 gpm. The design flow rate for the FGD 

wastewater treatment system is 75 gpm. 

 The secondary hydrocyclone overflow is transferred directly to the equalization 

tank, where intermittent flows from the hydrocyclone are equalized allowing the 

plant to pump a constant flow rate of FGD wastewater through the treatment 

system. The equalization tank also receives wastewater from the filtrate sump, 

which consists of filter press filtrate and treated effluent recycle. 
 The wastewater flows from the equalization tank to reaction tank 1, where 

hydrated lime is added to raise the pH of the wastewater from 5.6 to about 8.5 

S.U. Reaction tank 1 also receives some of the sludge from the downstream 

primary clarifier which provide seed crystals for gypsum nucleation.

 From reaction tank 1, the wastewater flows to the primary clarifier. The clarifier 

contains approximately 2 to 4 feet of settled solids in the bottom of the clarifier. 

Pleasant Prairie adds a polymer to the primary clarifier to aid the settling of the 

solids. 

 The overflow from the primary clarifier flows to reaction tank 2, where the plant 

adds organosulfide and hydrochloric acid. When the plant first began operating 

the treatment system, they used TMT 15® as the organosulfide. Since that time, 

the plant has switched to using Nalmet® 1689, which is an organosulfide that has 

a longer polymer chain, and therefore, a higher molecular weight, which helps aid 

in the settling of precipitates. Pleasant Prairie also began adding hydrochloric 

acid to reaction tank 2, which wasn’t in the initial design of the treatment system, 

because the plant determined that the they got better removals of mercury when 

the treatment system operated at a lower pH. The pH in reaction tank 2 is 

targeted at 7.0 to 7.2 S.U.

 The wastewater flows next to reaction tank 3, where ferric chloride is added. The 

wastewater then flows to the flash mix tank, where polymer is added. From the 

flash mix tank, the wastewater flows to the flocculation tank where a gentler 

mixing takes place.

 The wastewater from the flocculation then flows to the secondary clarifier. The 

secondary clarifier settles the solids created from chemical conditioning steps. 

The secondary clarifier is an inclined-plate lamella separator type clarifier. 

Hydrochloric acid is can be added to the overflow from the secondary clarifier to 

meet discharge standards for pH. Under normal operation, hydrochloric acid is 

only added to reaction tank 2.

 The treated wastewater is collected in two effluent tanks prior to discharging to 

Lake Michigan.

 Pleasant Prairie commingles the effluent from the FGD wastewater treatment 

system with other plant wastewaters, typically cooling tower blowdown, at a ratio 

of 30:1 to meet the final outfall mercury and chloride limits, 80 ng/L and 1,514 

mg/L, respectively. 

 The plant stated that when they chlorinate the cooling system, they do not 

discharge cooling tower blowdown. Because there is no discharge of cooling 

tower blowdown during chlorination, the plant does not discharge the treated 

FGD wastewater because there is not enough other plant wastewaters to 

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commingle with the FGD wastewater to meet the final outfall mercury limit. The 

treated wastewater is held in the effluent tank during chlorination until 

discharged. [QUESTION FOR PLEASANT PRAIRIE: How long can the plant 

keep from discharging without needing to go into recirculation mode?]

 The FGD wastewater treatment system typically operates Monday through 

Saturday. The plant performs weekly maintenance on the system starting Saturday 

evening. This maintenance includes draining and flushing the second clarifier, to 

avoid flocculation build up, which can impact its performance.

 The first FGD scrubber, installed in November 2006, ran for several months with 

100% recirculation before blowing down to the FGD wastewater treatment 

system. The plant had several start up and performance issues with the FGD 

wastewater treatment system and did not discharge from the system until the end 

of calendar year 2007. Pleasant Prairie was able to operate the wastewater 

treatment system in recirculation mode for a long period of time because the 

chlorides in the system do not build up quickly due to the low chlorine content in 

the PRB coal.

 When the plant does not blowdown for several weeks, fines and colloidal particles 

begin to build up in the FGD wastewater treatment system because they are being 

recirculated throughout the system without being discharged. As the fines 

concentration begins to increase, the mercury concentration also begins to 

increase. If the mercury concentration rises above the NPDES permit limit, the 

plant is unable to discharge and, therefore, the mercury concentration would 

continue to rise. To help remove the fines and associated mercury from the 

wastewater, Pleasant Prairie installed a set of cartridge filters that can be used as a 

polishing step. The plant used the cartridge filters to remove the mercury from the 

FGD wastewater treatment system after the initial start up phase. The plant is still 

able to treat the wastewater through the cartridge filters, but they try not to do this 

unless necessary because the filters are expensive. Currently the plant can stop 

discharging for approximately a week before they can notice chlorine 

concentrations increases. [QUESTION FOR PLEASANT PRAIRIE: How 

frequently do the cartridge filters need to be replaced when used?]

 Pleasant Prairie has made a few modifications to the FGD wastewater treatment 

system since the system first began operating in early 2007. The following is a list 

of the modifications Pleasant Prairie has made to the FGD wastewater treatment 

system:

 Changed the type of organosulfide used in the system from TMT 

15® to Nalmet® 1689; 

 Added a hydrochloric acid addition point to reaction tank 2 

because the system achieves better mercury removals at a lower 

pH; 

Comment [dml4]: PGK: The working volume of 

the two effluent tanks is about 18,000 gallons so the 

plant can interrupt discharge of treated effluent for 

about 8 hours before needing to go into recirculation 

mode. 

Comment [dml5]: Cartridge filters were 

replaced every 24-36 hours based on flow rate and 

solids loading. 
 Bypassed a set of sand filters which were located after the 

secondary clarifiers because of scaling issues; and 

 Added the capability to use cartridge filtration to remove colloidal 

particles from the wastewater after the effluent tanks, which may 

build up in the system if the plant recirculates the wastewater 

without discharging for several weeks; however the cartridge 

filtration is not used regularly.

Wastewater Treatment System Performance 

 Pleasant Prairie is required to sample mercury twice per week, according to their 

NPDES permit. The plant also collects samples Monday through Friday off the 

secondary clarifier for confirmation of system performance. The plant uses a 

Method DMA 80 Hg analyzer to test mercury, which is comparable to Method 

1631E, but is usually biased high. For example, some samples analyzed using 

Method 1631E resulted in mercury concentrations of 0.22 to 0.25 ppb, and the 

Method DMA 80 resulted in mercury concentrations of 0.35 to 0.4 ppb.

 When mercury concentrations start to approachexceed 1.12 or 1.3 ppb;, the plant 

will begin discharging from the FGD wastewater treatment system in batches. The 

wastewater is transferred to one of the effluent tanks and then isolated when it is 

full. The plant will then analyze a sample for mercury to ensure it is below the 

permit limit of 1.5 ppb. Once the mercury concentration is confirmed, the plant 

discharges the wastewater from the effluent tank. 

 The plant staff has been working to optimize the performance of the system and

typically achieves tries to keep the effluent mercury concentrations levels below 

0.4 ppb. The wastewater treatment system is currently achieving the lowest 

mercury concentrations since the installation of the system without the use of 

polishing filtration, 0.25 ppb.

 FGD wastewater from units burning PRB coal has a higher influent mercury 

concentration, compared to bituminous coal. PRB coal produces an FGD 

wastewater treatment influent with a mercury concentration of 2,000 ppb ± 500, 

compared to 500 ppb for an influent concentration from bituminous coal. 

 Pleasant Prairie believes that high mercury levels in the FGD wastewater are a 

result of the scrubber chemistry and burning PRB coal. Pleasant Prairie stated that 

the mercury concentration measured in the effluent from their treatment system is 

an order of magnitude higher than the effluent from a similar treatment system 

burning bituminous coal at another of We Energies facility. The average mercury 

concentration reached after treatment for bituminous coal is 0.03-0.04 ppb; some 

even reaching 14 ppt.

 Pleasant Prairie has performed pilot tests using microfiltration for the reduction of 

mercury and other heavy metals in the final effluent. In September/October 2008, 
the plant performed a series of membrane pilot tests. The pilot tests used a 1 gpm 

slip stream from the primary clarifier effluent as the basis for the study. The pilot 

tests included the following:

 Pleasant Prairie tested Siemens’ Memcor® technology microfiltration 

system. The system achieved effluent mercury concentrations of 0.1 ppb, 

but the system experienced significant scaling issues. [QUESTION FOR 

PLEASANT PRAIRIE: Please clarify if the plant tested a microfiltration 

or ultrafiltration system. What specific configuration did you test at the 

plant? How long was the system tested at the plant? How quickly did 

scaling occur?]

 Pleasant Prairie tested GE’s Zeeweed membranes during a 2-3 week 

period, but not the entire GE Zeeweed microfiltration system. The pilot 

test involved the use of organosulfide, iron co-precipitation and 

microfiltration that , which also achieved effluent mercury concentrations 

of 0.1 ppb. [QUESTION FOR PLEASANT PRAIRIE: Please clarify if the 

plant tested a microfiltration or ultrafiltration system.] The microfiltration 

system incorporated a small Zeeweed hollow fiber membrane module that 

operated at about 1 gpm. The Zeeweed membranes were removed and 

manually cleaned used air scouring and backwashing to remove scale 

from the systemseveral times during the duration of the pilot test. Pleasant 

Prairie stated that the system performed well and appeared to be more 

promising than the Memcor® system. However, the plant stated that they 

would want the system to be tested on a larger scale before they would 

purchase the system. 

 Pleasant Prairie also tested an absorptive media system and an iron 

cementation system. 

 Selenium levels are also higher in PRB coal than bituminous coal. Total selenium 

in the influent FGD wastewater at Pleasant Prairie is about 15,000 ppb, mostly in 

the solids phase. The effluent from the system is between 3,000 and 5,000 ppb. 

Pleasant Prairie believes that the selenium in their wastewater is difficult to treat 

because there is more selenate (which has a higher solubility) in the system, than 

selenite. Pleasant Prairie believes the presence of more selenate is due to the 

scrubber chemistry associated with PRB coal. 

Information for Sampling 

 EPA identified the FGD wastewater treatment system influent sampling point as 

the tap off the secondary hydrocyclone. EPA would use this sample to represent 

the influent to the FGD wastewater treatment system. Pleasant Prairie stated that 

they could install a smaller hose barb on the tap to accommodate the sample 

collection. There is plenty of space surrounding the secondary hydrcyoclone in 

order to set up tables and store coolers/supplies. 

Comment [dml6]: This pilot, described in detail 

in EPRI report 1020576, used the Memcor hollow 

fiber microfiltration with flow inside to outside as a 

pre-filter to the solids absorption tanks. The system 

was only tested over a one week period due to 

significant scaling which developed in less than 24 

hours of operation. 

Comment [dml7]: No -- The entire Zeeweed 

system is a microfiltration unit that includes an 

integrated air scour and chemical cleaning system. 

This standard GE Zeeweed unit was not tested 

because of potential corrosion concerns. We did, 

however, incorporate a small Zeeweed hollow fiber 

membrane module (0.1 micron, with flow outside to 

inside) into a custom built system used in the pilot 

test described in this paragraph. Reference: EPRI 

report 1016813. 
 EPA identified the FGD wastewater treatment system effluent sampling point as 

the tap located after the effluent tank, prior to recirculation or discharge, at the 

sample panel. Prairie stated that they could install a smaller hose barb on the tap 

to accommodate the sample collection. There is available space in the FGD 

wastewater treatment building to set up tables and store coolers.

 Pleasant Prairie stated that all on-site sampling personnel would be required to 

attend a 30 minute health and safety training session. In case of emergencies 

during the sampling episode, the samplers should contact the control room 

immediately. Additionally, all personnel will be equipped with key phone 

numbers and sound awareness cards for any sound signals occurring at the plant 

during sampling.
Table 1. Site Visit Attendees 

Name Organization (Representing) Telephone E-mail Elizabeth Hellman We Energies 414-221-3235 elizabeth.hellman@we-energies.com Pete Kutzora We Energies 414-221-3926 pete.kutzora@we-energies.com David Lee We Energies 414-221-2158 david.lee@we-energies.com Ed Morris We Energies 262-947-5625 ed.morris@we-energies.comDonna Hill Southern Company/UWAG 205-587-4846 dbhill@southernco.com Jezebele Alicea US EPA 202-566-1755 alicea.jezebele@epa.gov Ron Jordan US EPA 202-566-1003 jordan.ronald@epa.gov TJ Finseth ERG 703-633-1698 thomas.finseth@erg.com Elizabeth Sabol ERG 703-633-1659 elizabeth.sabol@erg.com