Project No.: 0172.07.029.030 DISTRIBUTION

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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. Pe te Kutzora. I explained to Mr. Kutzora that I was calling to confirm the operation of the FGD systems a nd FGD wastewater treatmen t systems at the Pleasant Prairie, Elm Road, and Oak Creek powe r plants. Some information provided during this call is not included in this document, because it was identifie d 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 un its and associated FGD scrubbers we re planned to begin operation in

2010.

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

Mr. Kutzora confirmed that the steps in the F GD 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 change s had been made to the FGD wastewater treatment system. The plant moved the hydrochloric acid addition (for pH adjustment) located after the s econdary clarifier to the same tank with the organosulfide addition located after the primary clarifier. The plant also removed the gravity filtrationstep at the end of the treatment system due to problems with scaling. These change s 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 treatm ent system is primarily trying to optimize mercury removal. Mr. Kutzora explained that the mercury concentration level that n eeds to be achieved by the system is 1.5 parts per billion (ppb), which is an internal monito ring limit prior to comminglin g the FGD wastewater with the cooling tower blowdown. Mr. Kutzor a explained that the F GD wastewater treatment system is achieving an effluent mercury concentration of between 0.5 and 0.75 pa rts per billion (ppb) of me rcury. The final mercury effluent limits for the plant (after commingling with c ooling tower blowdown) is 80 parts per trillion (ppt).

Mr. Kutzora explained that in addition to the changes ma de to the hydrochloric acid addition and the removal of the gravity filtration, the plant change d 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 precip itate the high levels of dissolved mercury. Therefore, the plant began us ing Nalmet 1685 (a Nalco product) in April 2009. Mr. Kutzora stated that the plant is stil l conducting jar testing to de termine 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 wastew ater treatment system is 40 gallons per minute (gpm).

Mr. Kutzora explained that the F GD wastewater treatment system ge nerally operates and discharges continuously; however, the plant is unabl e to discharge the FGD wastewater when the plant is chlorinating the cooling water system. Pleasant Prairie has a permit limit th at they cannot discharge any chlorine in the cooling tower blowdown; therefore, they must wait until all the chlo rine is consumed in the cooling system before they discharge the cooling tower blowdown. Because they n eed to dilute the FGD wast ewater with the cooling tower blowdown to meet the 80 ppt effluent mercury c oncentration, Pleasant Prairi e holds the FGD wastewater treatment effluent in a storage tank until the plant resu mes 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 pl ant will re-circulate primar y clarifier effluent back to the equalization tank and they wi ll drain and clean the other downstr eam reaction tanks and clarifiers.

Elm Road/Oak Cree k 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 e xplained that the Elm Road Power Plan t consists of two newly constructed units that are located adjacent to the Oak Creek plant.

Mr. Kutzora explained that Elm Road will begin opera ting 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 expl ained 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 Cree k is installing new FGD systems that are expected to be operating

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

Mr. Kutzora explained that the Oak Cr eek units currently operate SCRs a nd the Elm Road generating units will operate SCRs. Mr. Kutzora stated that the SCRs at both of the plan ts are/will be operated year round.

Mr. Kutzora explained that FGD wastew ater treatment system at Elm Road is nearly identical to the FGD wastewater treatment system at Pleasan t Prairie. However, one of the bigg est differences between the Pleasant Prairie FGD wastewater treatment syst em 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 us ed 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 planni ng 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 Ro ad FGD wastewater treatment system is primarily trying to optimize the removal of mercury. Mr. Kutzora expl ained 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 syst em 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 syst em is expected to operate and discharge continuously.