Comment submitted by Terry Coughlin, We Energies, Pleasant Prairie Power Plant

To Whom It May Concern: On behalf of Wisconsin Electric Power Company, doing business as We Energies ("We Energies" or the "Company"), thank you for the opportunity to submit comments on this proposed EPA method, 40 CFR Part 51 (March 25, 2009). We Energies is an investor-owned utility with electric generating facilities in Wisconsin and Michigan, serving more than 1.1 million electricity customers in southeastern Wisconsin and in the Upper Peninsula of Michigan, and more than one million natural gas customers in Wisconsin. As such, we have fossil fueled power plants whose emissions will be "judged" by this proposed measurement method. We Energies supports the efforts of U.S. EPA's staff to develop accurate emission measurement efforts. In acknowledgement of the current problems associated with Methods 201A and 202, which this proposed method will amend, the Company initiated financial support for a program of condensable particulate measurement method development and testing managed by the Electric Power Research Institute (EPRI) in 2006-2008. Results from that program have been shared by EPRI staff with EPA staff working on revised methods 201A and 202. The need for an accurate condensable particulate matter measurement method is very important to us since our fossil fueled generating facilities are subject to very strict PM10 emissions limits. In response to the proposed method development work conducted by EPA staff, we conducted unique tests for the measurement of condensable particulate matter on Unit 1 at our Pleasant Prairie Power Plant in January 2009. The Pleasant Prairie Plant is sub-bituminous coal-fueled and is equipped with SCR for NOx reduction; cold side ESPs for particulate capture and wet FGDs for SO2 capture. Tests were conducted simultaneously at the exit of the wet FGD in a “wet” stack using the three individual methods sampling trains. The tests included the former (Methods 201A and 202) as well as the amended EPA condensable particulate matter measurement methods. In addition, we also included tests using the Controlled Condensate Method (CCM) for sulfuric acid mist. A complete copy of this test program and its results is attached to our comment submittal. The test results indicate that the amended condensable particulate measurement method results are not significantly different from results obtained from the existing version of Method 202. When both of these results are compared with the sulfuric acid mist measurements obtained with the CCM, a high bias relative to the CCM results was observed.