### MEMORANDUM

TO: Ron Jordan , EPA

FROM: Elizabeth Sabol , ERG

DATE: 1 8 September 2009

SUBJECT: Notes from Pre

- Visit Call with Consumers Energy and Karn/Weadock

P ower P lants on September 14, 2009

EPA h eld a telec o nf erence with staff from Consumers Energy and the Karn/Weadock power plant s on Monday, September 14, 2009 at 2 : 0 0 P M to discuss the operations at the power plant s in preparation for the scheduled EPA site visit on Tuesday, September 22, 2009 . The following

people participated in the call:

Consumers Energy

Jenny Crawford

Gary Dawson

Harold (JR) Register

Jessica Woycehoski

Karn/Weadock P ower P lant s

Robert o Falco

UWAG

Donna Hill

EPA

Ron Jordan

Jezebele Alicea

ERG

Sarah Holman

Elizabeth Sabol

This memorand um summarizes the teleconference discussion points

.

Background on EPA Study of the Steam Electric Industry

EPA provided background on the study of the steam electric industry, highlighting that the study

evolved from research of publically available info rmation to a data collection effort including

site visits, wastewater sampling, and a questionnaire sent to nine companies. The main focus of

the study was to characterize flue gas desulfurization ( FGD ) and ash sluice wastewater and

treatment systems

.September 1 8 , 2009

Page 2

EP A discussed that as the study is concluding, there are some data gaps remaining

. The

Karn/Weadock site visit should help to fill in some of these data gaps , such as ash operations for

oil

- fired generating units and conversions from wet to dry fly ash handl ing system s

.

Purpose of the Site Visit

EPA stated that the main purpose of the site visit at the Karn/Weadock plant s is to obtain

information regarding the changes involved with the conversion of the wet fly ash handling

system to a dry system and the operation of the oil

- fired units. EPA is interested in understanding

the characteristics of ash generated from oil

- fired units, the amount produced, and if the ash is

handled wet or dry.

EPA requested that the following points of the fly ash handling con version be discussed and/or

toured during the site visit:

**•** The specific parts of the wet system that were removed;

**•** The specific parts of the dry system that were added and their connection points ;

**•** Any footprint issues with the conversion; and

**•** S hutdown time involved with the conversion.

Brief Introduction/Discussion of the Plant

EPA reviewed the major discuss ion topics for the site visit:

**•** General plant information/background ;

**•** D ry fly ash handling system conversion;

**•** Oil ash (when / how generated / handled);

**•** As h ponds; and

**•** Landfills.

Consumers Energy stated that oil

- fired units at the Karn/Weadock power plants are peaking units

and run rarely . The oil units have run less than usual this summer due to lower than usual air

temperatures. These units are capable of using oil or natural gas and have recently been using

natural gas. These units do not produce much ash with oil use due to relatively low boiler

temperatures

. The oil ash that is generated is vacuumed out of the boilers and is trucked off site

.

Site V isit Logistics

**•** EPA stated that the site visits conducted during this study have usually consisted

of the following:

o Check in

o Safety briefing

o Introduction to the plant

o Tour

o Debrief from the tour/questionsSeptember 1 8 , 2009

Page 3

**•** EPA stated that EPA/ERG will come prepared with har d hats, steel

- toed shoes,

safety glasses, and hearing protection for the tour.

**•** EPA stated that there will be four EPA/ERG staff on the site visit : Ron Jordan and

Jezebele Alic ea

, EPA and Sarah Holman and Elizabeth Sabol, ERG.

**•** EPA stated that during the sit e visit they would like to take photos to aid in the

preparation of notes from the visit. EPA stated that Consumers Energy will

receive a copy of all photo s taken and will be able to flag any photos as

confidential.

**•** EPA confirmed directions to the Karn/We adock power plants with Consumers

Energy.

**•** EPA

, Consumers Energy , and the Karn/Weadock power plants agreed to begin

the site visit at 7:30 AM EDT on Tuesday , September 22, 2009 . Co nsumers Energy , Karn/Weadock, and EPA plan to have lunch at the power plant.