Project No.: 0172.07.029.030 DISTRIBUTION 

Page _1_ of __1_

Project Name: Steam Electric Rulemaking 

TELEPHONE CALL RECORD 

 Outgoing Call 

Date: 12/01/09 Time: 03:50 pm EST 

Company Name: We Energies 

 Pleasant Prairie Power Plant 

 Elm Road Power Pant 

 Oak Creek Power Plant 

 

Contact Name: Pete Kutzora 

Phone No.:(414) 221-3926 

Name: TJ Finseth Eastern Research Group

GENERAL SUBJECT : We Energies FGD Systems and FGD Wastewater Treatment Systems Operation and Verification 

 

TOPICS DISCUSSED AND ACTION TAKEN 

On Tuesday, December 1, 2009 at 3:50 pm I contacted Mr. Pete Kutzora. I explained to Mr. Kutzora that I was 

calling to confirm the operation of the FGD systems and FGD wastewater treatment systems at the Pleasant 

Prairie, Elm Road, and Oak Creek power plants. Some information provided during this call is not included in 

this document, because it was identified as confidential business information. 

I first asked questions regarding the operations at the Pleasant Prairie Power Plant. 

Pleasant Prairie Power Plant 

Mr. Kutzora confirmed that Units 1 and 2 operate limestone forced oxidation FGD systems and that no 

additives are used in the FGD system. 

Mr. Kutzora explained that no new units and associated FGD scrubbers were planned to begin operation in 

2010. 

Mr. Kutzora confirmed that Units 1 and 2 still operate SCRs and explained that the SCRs operate year round. 

Mr. Kutzora confirmed that the steps in the FGD wastewater treatment system consisted of: 

 Equalization tank; 

 pH adjustment (lime addition); 

 Primary clarification; 

 Organosulfide and hydrochloric addition; 

 Ferric chloride addition; 

 Mixing tank; 

 Flocculation tank; 

 Secondary Clarification; and 

 pH adjustment (hydrochloric acid addition). 

Mr. Kutzora explained that two changes had been made to the FGD wastewater treatment system. The plant 

moved the hydrochloric acid addition (for pH adjustment) located after the secondary clarifier to the same tank 

with the organosulfide addition located after the primary clarifier. The plant also removed the gravity filtration 
step at the end of the treatment system due to problems with scaling. These changes are incorporated into the 

treatment steps identified above. 

Mr. Kutzora explained that the company U.S. Filter, which is now Siemens, designed the FGD wastewater 

treatment system. 

Mr. Kutzora confirmed that the FGD wastewater treatment system is primarily trying to optimize mercury 

removal. Mr. Kutzora explained that the mercury concentration level that needs to be achieved by the system is 

1.5 parts per billion (ppb), which is an internal monitoring limit prior to commingling the FGD wastewater with 

the cooling tower blowdown. Mr. Kutzora explained that the FGD wastewater treatment system is achieving an 

effluent mercury concentration of between 0.5 and 0.75 parts per billion (ppb) of mercury. The final mercury 

effluent limits for the plant (after commingling with cooling tower blowdown) is 80 parts per trillion (ppt). 

Mr. Kutzora explained that in addition to the changes made to the hydrochloric acid addition and the removal of 

the gravity filtration, the plant changed the type of organosulfide used. Mr. Kutzora explained that the plant 

was previously using TMT, but the plant found that it was unable to effectively precipitate the high levels of 

dissolved mercury. Therefore, the plant began using Nalmet 1685 (a Nalco product) in April 2009. Mr. 

Kutzora stated that the plant is still conducting jar testing to determine if other organosulfides are more effective 

at removing mercury from the plant FGD wastewater. 

Mr. Kutzora explained that no other waste streams are treated by the FGD wastewater treatment system. Mr. 

Kutzora also explained that the typical flow rate through the FGD wastewater treatment system is 40 gallons per 

minute (gpm). 

Mr. Kutzora explained that the FGD wastewater treatment system generally operates and discharges 

continuously; however, the plant is unable to discharge the FGD wastewater when the plant is chlorinating the 

cooling water system. Pleasant Prairie has a permit limit that they cannot discharge any chlorine in the cooling 

tower blowdown; therefore, they must wait until all the chlorine is consumed in the cooling system before they 

discharge the cooling tower blowdown. Because they need to dilute the FGD wastewater with the cooling 

tower blowdown to meet the 80 ppt effluent mercury concentration, Pleasant Prairie holds the FGD wastewater 

treatment effluent in a storage tank until the plant resumes the cooling tower blowdown discharge. Mr. Kutzora 

stated that discharge may be stopped for four to six hours during these chlorination periods. 

Mr. Kutzora also stated that the plant occasionally performs maintenance on the FGD wastewater treatment 

system on Sundays. During these maintenance times, the plant will re-circulate primary clarifier effluent back 

to the equalization tank and they will drain and clean the other downstream reaction tanks and clarifiers. 

Elm Road/Oak Creek Power Plants 

I then asked questions regarding the operations at the Elm Road and Oak Creek Power Plants. 

Mr. Kutzora explained that the Oak Creek plant consists of four coal-fired units that have been operating for 

roughly 40 years. Mr. Kutzora also explained that the Elm Road Power Plant consists of two newly constructed 

units that are located adjacent to the Oak Creek plant. 

Mr. Kutzora explained that Elm Road will begin operating Unit 1 sometime in December 2009 and Unit 2 is 

expected to begin operating in September 2010. Both units have an associated FGD system that will be running 

when the units begin operation. Mr. Kutzora also explained that Elm Road will operate a FGD wastewater 

treatment system that will begin operating shortly after Unit 1 starts operating. 

Mr. Kutzora explained that Oak Creek is installing new FGD systems that are expected to be operating 

sometime in 2012. Mr. Kutzora stated that the Oak Creek plant will operate two FGD systems for the four units 
(i.e., one FGD system for a pair of units. Mr. Kutzora also stated that the plant does not plan to use any 

additives in the FGD system. 

Mr. Kutzora explained that the Oak Creek units currently operate SCRs and the Elm Road generating units will 

operate SCRs. Mr. Kutzora stated that the SCRs at both of the plants are/will be operated year round. 

Mr. Kutzora explained that FGD wastewater treatment system at Elm Road is nearly identical to the FGD 

wastewater treatment system at Pleasant Prairie. However, one of the biggest differences between the Pleasant 

Prairie FGD wastewater treatment system and the planned Elm Road wastewater treatment system is that the 

Elm Road treatment system may also be used to treat some bottom ash wastewater. Additionally, Mr. Kutzora 

stated that the Elm Road treatment system will be used to treat the FGD wastewater from Oak Creek when 

those units begin operating the FGD systems. The Elm Road wastewater treatment system consists of the 

following steps: 

 Purge tank; 

 Reaction tank 1 (lime and polymer addition); 

 Primary clarifiers (2 operated in parallel); 

 Equalization tank; 

 Reaction tank 2 (ferric chloride and hydrochloric acid addition); 

 Reaction tank 3 (organosulfide addition); 

 Mix tank (polymer addition); 

 Secondary clarifier; and 

 Gravity filtration. 

Once the FGD wastewater is treated in the lime addition reaction tank, the wastewater is split to two primary 

clarifiers, each with a 60 percent load capability. Mr. Kutzora explained that they constructed the two primary 

clarifiers to allow for redundancy for maintenance purposes. The effluent from the two primary clarifiers is 

re-combined upon entering the equalization tank. 

Mr. Kutzora explained that Elm Road is not planning on making any changes to the operation of the FGD 

wastewater treatment system. However, the treatment system allows flexibility to feed different chemicals into 

different reaction tanks in order to optimize the removal of target analytes, depending on the needs of the plant. 

Mr. Kutzora stated that the Elm Road FGD wastewater treatment system was designed by West Tech, which is 

located in Salt Lake City. 

Mr. Kutzora confirmed that the Elm Road FGD wastewater treatment system is primarily trying to optimize the 

removal of mercury. Mr. Kutzora explained that the plant has an internal monitoring limit of 1.5 (ppb) mercury 

for the effluent from the treatment system. Mr. Kutzora stated that the final effluent limit for the mercury after 

commingling with cooling tower blowdown is 1.3 ppt. 

Mr. Kutzora explained that the Elm Road FGD wastewater treatment system is designed for 400 gallons per 

minute (gpm); however, he expects that the typical flow rate in the FGD wastewater treatment system will be 

200 gpm. 

Mr. Kutzora explained that the Elm Road FGD wastewater treatment system is expected to operate and 

discharge continuously.